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UNITED STATES..
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NTA AGENCY UNITED STATES5 PEosNRtVE OGIfIRfOiONceN 1MS
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AL PROTECTION AGENCY
Boston, MA 02109
Sent via Electronic Mail (Dated as shown on electronic signature)
Mr. Chris Predella, Owner
Babe's Lawn Care, Inc.
345 Sturbridge Road
Brimfield, MA 01010
babeslawncare@hotmail.com
Subject: June 28, 2023 EPA Inspection of Babe's Lawn Care
Dear Mr. Predella,
On June 28, 2023, the U.S. Environmental Protection Agency performed an inspection at Babe's
Lawn Care, Inc., located at 345 Sturbridge Road, Brimfield, MA (" the Facility " or " site "),
regarding compliance with the National Pollutant Discharge Elimination System (" NPDES ")
program of the Clean Water Act. A copy of the inspection report and associated photo album are
enclosed in this letter.
During the inspection, EPA inspectors observed areas of clearing and disturbed soil. The
inspectors verified that the Facility does not have any NPDES permit coverage for stormwater
discharges associated with construction activity at the site, under EPA's Construction General
Permit (" CGP ").
In general, any " construction activity " that will disturb one or more acres of land and discharges
stormwater to waters of the U.S. must obtain NPDES permit coverage. This disturbance includes
those construction activities that are part of a common plan of development that will
cumulatively disturb one or more acres of land and discharge stormwater to waters of the U.S.
" Construction activities, " as defined in CGP Appendix A, includes but is not limited to earth-
disturbing activities, such as the clearing, grading, and excavation of land, and other
construction - related activities (e.g., grubbing, stockpiling of dredged or fill materials; placement
of raw materials at the site) that could lead to the generation of pollutants.
The expansion efforts being conducted at Babe's Lawn Care appear to include construction
activities, as defined above. Should your Facility plan to disturb over an acre of land, CGP
coverage may be required; if so the Facility would need to send a Notice of Intent (" NOI ") to
discharge stormwater at EPA's NeT NPDES eReporting Tool at least 14 calendar days before
commencing construction activity.
1 https://www.epa.gov/system/files/documents/2022-01/2022-cgp-final-appendix-a-definitions.pdf
2 https://npdes-ereporting.epa.gov/net-cgp/action/login
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You may refer any questions related to technical issues in this letter to Damian Bednarz of my
staff at 617-918-1482 or bednarz.damian@epa.gov. Legal issues may be directed to Jeff Kopf,
Senior Enforcement Counsel, at (617) 918-1796 or kopf.jeff@epa.gov.
TODD BORCI Digitally Date: 2023.08.22 signed by 11:44:59 TODD BORCI -04'00 '
Sincerely,
Todd Borci, Manager, Water Compliance Section 1
Enforcement and Compliance Assurance Division
Enclosures:
Babe's Lawn Care Inspection Report and Photo Album
CCs (electronic only):
Judith Schmitz, MA DEP
Jeff Kopf, Senior Enforcement Counsel, US EPA
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