babylon riding center

In addition, as discussed further below, the proof adduced at the hearing, conducted in respondent's absence, demonstrates by a preponderance of the evidence that respondent committed the violations charged in the complaint. Consequently, the violation is ongoing since staff's site visit on May 1, 2018. There is a lot to remember when you first start learning to ride a horse. Visits of Department staff to the site, subsequent to the May 1, 2018 inspection, confirmed the continued presence of the manure pile (see Hearing Report at 5 [Finding of Fact No. [3] During the May 1, 2018, site visit, Department staff took a set of 4 photographs identified as Exhibit 12. [Finding of Fact No. 4. 1 at 26:05-26:28. (See Exhibit 4; Exhibit 5, Photo Nos. In addition, the plan is to detail the type of native plants that will be replanted in the cleared areas. 412 Sweet Hollow Rd., Melville, 631-616-9656,ddrfarm.com, DEEP HOLLOW RANCH Respondent. Respondent violated 6 NYCRR 663.4(a) when it filled a portion of Freshwater Wetland BW-1 without a permit from the Department. 15], 10). Consequently, the violation is ongoing since Department staff's inspection on February 28, 2017. ), On May 1, 2018, no erosion control or catch basin existed between the manure pile and the Carlls River. Respondent did not have a permit from the Department to undertake this regulated activity. We are only 5 minutes from the LIRR. 1992-07-06 Incorporated. Staff requested restoration of the site by removing the fill from the wetland areas as well as the affected adjacent areas. Department staff went to the site on May 1, 2018, and observed a large pile of horse manure and bedding on the site within the boundary of Freshwater Wetland BW-1, and adjacent to the Carlls River. The coronavirus pandemic has pushed many Long Islanders to find social-distance-friendly ways to get out and appreciate the place they call home. This state forest is home to five horseback riding trails that make up almost 20 miles of bridle paths in addition to trails for mountain biking, hiking, and more. The record developed on December 17, 2021, establishes the following. This case was filed in Suffolk County Superior Courts, with Stephen Hackeling presiding. I hereby direct that the remedial action plan include a multi-year monitoring program with respect to the area that is restored that will provide a sufficient period of time to evaluate the regrowth of the plants and provide for any necessary replacement of any replantings that do not survive or otherwise need to be replaced. Based on 1 salaries posted anonymously by Babylon It Operations Analyst employees in Worcester Park, England. Horses are for everyone, says Diana Russo, owner of DDR Farm in Melville, which offers lessons and trail rides. We held my daughters Girl Scout Troops end of the year party at this stable. USA Business Directory. 1 at 37:27-38:24. Horseback riding. Babylon Riding Center Inc, 1500 Peconic Ave - N Babylon, NY.11704-5212, 516-587-7778 Bedford Riding Lanes Assoc, 69 Stone Hill Rd - Bedford, NY. I wasn't born on the back of a horse or really anywhere near a barn. ECL 17-0701 and 17-0803, as well as 6 NYCRR 750-1.4(a) prohibit any person from discharging pollutants to the waters of the State without first obtaining a State Pollutant Discharge Elimination System (SPDES) permit pursuant to ECL article 17, titles 7 or 8, and 6 NYCRR part 750. [2] The audio recording of the hearing consists of two segments. Write Review. He was at the site during staff's May 1, 2018, inspection. Accordingly the payable portion of the civil penalty will be sixty-six thousand five hundred dollars ($66,500) which respondent is to submit to the Department within sixty (60) days of the service of this order upon it. Also, don't forget to mention Hubbiz to Babylon Riding Center Inc. 1 at 18:18-18:39). Rides are one hour long and operate every day, weather permitting. For the rider and viewers convenient our indoor arena is located under the same roof as our office and barn, so no need to face the unpleasant . of Environmental Conservation. ), 2. YEARS IN BUSINESS. The manner of use of the front-end loader at the site (scooping up waste material from the trench and depositing the waste into the Carlls River) would be a "point source" and constitutes a "discernible, confined and discrete conveyance" from which pollutants are being discharged (see 6 NYCRR 750-1.2 [a][67]). And the best part is, theres no worrying about whether or not the horses are wearing masks! Call (631) 581-9477 for more details. Clearing vegetation from the adjacent area of a freshwater wetland is a regulated activity (see 6 NYCRR 663.4[d][23]). Useful 1. We offer an extensive lesson program, impeccable boarding facilities, camp programs . Photo No. CLOSED NOW. Whitepages is the most trusted online directory. Class I wetlands provide the most critical of the State's wetland benefits. Tony Russo has . On February 28, 2017, Department staff observed that respondent had placed fill on the southeast corner of the site, which is part of Freshwater Wetland BW-1. A comparison of the two aerial images shows that vegetation from an area measuring 50 ft by 120 ft. was cleared between October 26, 2015, and October 29, 2016. Department staff commenced this proceeding by service of a notice of hearing and complaint dated March 12, 2021. Respondent Babylon Riding Center, Inc., within thirty (30) days of the service of this order upon it, is directed to submit an approvable remedial action plan to the Department that: A. details the manner in which the fill that respondent placed in regulated freshwater wetland BW-1 and its adjacent area and the manure pile that it has created in the vicinity of the Carlls River will be removed and the location or locations to which the material will be relocated; B. provides information on respondent's restoration of the cleared areas of the site by the replanting of those areas with native plant species and the schedule for the replanting; and. Filling the adjacent area of a freshwater wetland is a regulated activity (see 6 NYCRR 663.4[d][20]). Development was started shortly after finishing NieR: Automata and to be an online Game as a Service. and 24 of the New York State Environmental Conservation Here's a list, photo, and description of all the different types of horse riding saddles associated with English and Western riding that you'll find. Pedal boats and rowboats are available for rent on the lake through the summer. New York. 6 and 8]; (6) a berm measuring 20 ft by 27 ft [Photos Nos. In the event that respondent fails to comply with any term or condition of this order, the entire penalty shall be immediately due and owing. Respondent filled eleven different areas on the site. ), 16. Sentai . Therefore, BRC violated 6 NYCRR 663.4(a). 10576-1424, 914-234-6585 The March 12, 2021, notice of hearing and complaint provide a concise statement of the relief requested. In the event that respondent fails to comply with any term or condition of this order, including but not limited to the implementation of the required remedial action plan to Department staff's satisfaction, the suspended amount of the civil penalty (that is, one hundred twenty-five thousand dollars [$125,000]) shall be immediately due and payable and shall be paid in the same manner and submitted to the same address as the non-suspended portion of the civil penalty. Department staff did not issue a permit to BRC either to conduct any regulated activities in or adjacent to Freshwater Wetland BW-1, or to discharge contaminated wastewater to the Carlls River (Recording No. The oldest working ranch in the United States, this family run business offers not only trail rides but one-of-a-kind beach rides along the Long Island Sound as well. In addition to the Town of Babylon parks, there are parks managed and owned by the State, County and surrounding Villages. Write Review. Department staff provided an affidavit of mailing by Karen Mascio, sworn to March 15, 2021. 2 at 2:22-4:11; 5:16-6:30; 13:00-13:21; see Exhibit 12. I speak from personal experience. Exhibit 12D is a photograph of a trench located next to the manure pile. [1] Based on five causes of action, staff seeks an order from the Commissioner that: (i) finds BRC in violation of various provisions of ECL articles 17 and 24, and implementing regulations; (ii) directs respondent to submit an approvable restoration plan; (iii) assesses a total civil penalty of $191,500; and (iv) grants such other and further relief the Commissioner may determine to be just and appropriate. Riding facility located in West Babylon New York. In addition, staff relied on aerial photographs of the property, as well as characteristics of the neighboring properties as references. The cleared wetland area measured 50 ft by 120 ft. Respondent did not have a permit from the Department to undertake this regulated activity. He did not assume the risk of an unsupervised ride. Due to the location of this waste, runoff during storm events would move from the manure pile to the Carlls River (see Hearing Report at 4-5 [Finding of Fact No. 1 at 18:15-19:57; 21:37-22:15; see also 16 Knoll Affidavit; Exhibit 10. Staff of the New York State Department of Environmental Conservation (Department staff) served Babylon Riding Center, Inc. (BRC or respondent), with a notice of hearing and complaint, dated March 12, 2021, alleging violations of New York State Environmental Conservation Law (ECL) articles 17 (Water Pollution Control) and 24 (Freshwater Wetlands), and implementing provisions of title 6 of the Official Compilation of Codes, Rules, and Regulations of the State of New York (6 NYCRR) parts 663 (Freshwater Wetlands Permit Requirements) and 750 (Water Pollution Control). Accordingly, the ALJ determined that respondent violated 6 NYCRR 663.4(a) with respect to the clearing of vegetation, and that the violations have been ongoing since February 28, 2017. 1 at 3:00-3:17.) Area hotels were quickly running out of available rooms, but my wife and I decided to ride out the storm and power outagesfor a bit, anyway.. After passing a chilly night in our heatless abode, we ventured forth to seek the basic human needs of warmth . 2 at 9:50-9:55). (Recording No. 3. On January 25, 2022, Damon Hanna An Infant Under The Age Of Fourteen et al. Be truthful - this review will help other consumers as well as the business. Visit our Help Center . Department staff served the notice of hearing and complaint upon BRC in a manner consistent with the regulations (see 6 NYCRR 622.3[a][3]). DEC Case No. [1] Department staff, in its first four causes of action, did not fully detail specific references (see 6 NYCRR 622.3[a][1][ii] [complaint must contain "a reference to the particular sections, subsections, paragraphs and subparagraphs of the statutes, rules and regulations alleged to have been violated"]). 1 at 36:30-37:00. PHOTOS AND 631-924-4670. 1500 Peconic Ave., West Babylon, 631-587-7778,babylonridingcenterny.com, BETHPAGE EQUESTRIAN CENTER In addition, the adjacent area limits the introduction of pollutants into the freshwater wetland. Affidavit of Mailing by Karen Mascio, sworn to March 15, 2021. Wouldnt it be nice to suffer less, Riding 101 with Catherine : Find Yourself A Circle of Good Horsemen, Meet the man who KNOWS how to ride and is helping me on my Journey. Located in West Hills County Park, DDR Farm provides scenic trail rides all year round. Staff is required to support its motion for a default judgment with enough facts to enable the ALJ and the Commissioner to determine that staff has a viable claim (see Matter of Samber Holding Corp., Order of the Commissioner, March 12, 2018, at 1 [citing Woodson v Mendon Leasing Corp., 100 NY2d 62, 70-71 (2003)]; see also 6 NYCRR 622.15[b][3], CPLR 3215[f]). The cleared area measured 50 ft by 120 ft, and a portion of it was located in the adjacent area of Freshwater Wetland BW-1. (See Exhibit 14; Recording No. A permit could be issued only after determining that the proposed activity satisfies a compelling economic or social need that clearly and substantially outweighs the loss of or detriment to the benefits that the Class I wetland provides. US Geological Survey Quadrangle - Bay Shore West Freshwater Wetlands Map for Suffolk County Map 34 of 39 Freshwater Wetland BW-1. For violating ECL article 24 and implementing regulation at 6 NYCRR part 663, staff requested $11,000 for each violation. It provides a bucolic feeling adjacent to the Southern State Parkway at exit 38 among densely developed neighborhoods. SUMMER CAMP! Therefore, BRC violated 6 NYCRR 663.4(a). Deer Hills Boarding and Grooming. The photographs depict the location of the piles of manure, fill, wood debris, and topsoil in relation to the adjacent area and the boundary of Freshwater Wetland BW-1. Babylon. 1 at 19:57-20:19. Department staff requests that respondent undertake remedial action to address the violations referenced in this proceeding (see Hearing Report at 10). According to staff, some violations that are the subject of this proceeding commenced in 2011 based on site visits conducted prior to February 2017. 57. Each cause of action is discussed below. (See Exhibit 4; Exhibit 5, Photo Nos. 1500 Peconic Ave With respect to the unpermitted wastewater discharge, ECL 71-1929 provides that a person who violates any of the provisions of titles 1 through 11 inclusive of article 17 (which includes the statutory provisions at issue here) and its implementing regulations, is liable for a penalty of not to exceed thirty-seven thousand five hundred dollars per day for each violation. They say either you have it, or you dont. BRC failed to answer the complaint. Riders have the . The provisions, terms and conditions of this order shall bind respondents Babylon Riding Center, Inc. and its agents, successors and assigns, in any and all capacities. Consequently, the violation is ongoing since staff's site visit on May 1, 2018. The first four causes of action allege violations of ECL article 24 (Freshwater Wetlands), and implementing provisions of 6 NYCRR part 663 (Freshwater Wetlands Permit Requirements). The Commissioner should assess a total civil penalty of $191,500. At some point, things begin to, Aureliano Equestrian: Learn the Fine Art of Horse Riding in a One-On-One Setting. Read the blog post to learn how you can safely light your horse's stable: We all know riding is a physical challenge. Each of the eleven areas filled is considered a separate violation. 0 (631) 667-0870. [4] Exhibit 10 is a set of two aerial photograph from Nearmap US, Inc. (See 13-23 Knoll Affidavit; Recording No. 20]). With respect to the wetland regulations, ECL 71-2303 provides for a civil penalty of $11,000 for every violation of ECL article 24 and its implementing regulations. From Business: Welcome to Suffolk Equestrian Academy, Our beautiful 10 acre facility is located in Long Islands prestigious Suffolk County. The activities undertaken in and adjacent to Freshwater Wetland BW-1 provided respondent with an economic benefit by expanding the working area of the equestrian center. Pay Less. In its complaint, Department staff set forth five causes of action, alleging that BRC: (1) Caused or allowed the clearing of vegetation in a freshwater wetland without a DEC permit and thereby violated ECL article 24 and 6 NYCRR part 663; (2) Caused or allowed the clearing of vegetation in the adjacent area of a freshwater wetland without a DEC permit and thereby violated ECL article 24 and 6 NYCRR part 663; (3) Caused or allowed the placement of fill in a freshwater wetland without a DEC permit and thereby violated ECL article 24 and 6 NYCRR part 663; (4) Caused or allowed the placement of fill in the adjacent area of a freshwater wetland without a DEC permit and thereby violated ECL article 24 and 6 NYCRR part 663; and, (5) Caused the discharge of contaminated wastewater into a freshwater river (Carlls River), and thereby violated ECL 17-0501, 17-0505, 17-0701, 17-0803 and 6 NYCRR 750-1.4(a).[1]. 48 Woodlot Rd., Ridge, 631-504-0085,nativity-riding-academy.com, NEW YORK EQUESTRIAN CENTER (Recording No. (See Exhibit 1; 6 Knoll Affidavit; Recording No. Pursuant to 6 NYCRR 663.4(a), all persons seeking to undertake activities on wetlands or their adjacent areas, which are not expressly exempted (see ECL 24-0701, and 6 NYCRR 663.3, and 663.4[d]), must obtain either a permit or a letter of permission from the Department . Furthermore, staff requested that respondent be directed to remove the manure pile from the site as to prevent the discharge of contamination to the Carlls River. 1 at 26:30-28:15; see 20 and 21 Knoll Affidavit.) Horse Stables Horse Rentals Horse Dealers. Consequently, the violations are ongoing since February 28, 2017. Adjacent areas also provide wildlife habitat benefits. Portions of the site are located in and adjacent to New York State freshwater wetland BW-1 and its regulated adjacent area. [1] See United States Geological Service (USGS) Quadrangle titled, Bay Shore West (Map 34 of 39 for Suffolk County). 1; 1-27 of 27 Results. Finally staff requests that respondent be directed to restore the cleared areas by replanting those areas with native plant species. 9]; (9) areas of topsoil located in and adjacent to Freshwater Wetland BW-1 at the southeast corner of the property [Photos Nos. (Image credit: Niday Picture Library via Alamy Stock Photo) Hammurabi had to be patient before he could expand, Leick noted. In addition, the manure pile was not covered. 2 at 13:50-15:35.). I disagree with some of the comments the horses are well treated and the facility treats their horses like they are family. The manure pile remains in place. 1. 0532 . The Commissioner has determined that "a defaulting respondent is deemed to have admitted the factual allegations of the complaint and all reasonable inferences that flow from them" (Matter of Alvin Hunt, d/b/a Our Cleaners, Decision and Order of the Commissioner, July 25, 2006, at 6 [citations omitted]). What our organization offers: Birthday parties. 631-348-1948. If you have any questions or suggestions regarding this matter, you are welcome to contact our customer support team. 18. Hundreds of thousands of residents were left without electricity, our home included. 345 . All proffered exhibits were received into the hearing record (Recording No. OHMS served a notice of hearing dated November 22, 2021, on BRC by first class mail. 2:22-4:11; see Exhibit 12. ), 3. At BusinessYab our purpose is to help people find great local businesses like dentists, hair stylists, restaurants, bars, hotels, local businesses. Upon good cause shown by respondent, Department staff at its sole discretion may extend (a) the submission date of the plan or (b) the date by which the remedial action plan shall be completed. STATE OF NEW YORK From Business: Babylon Riding Center, located in beautiful Belmont Lake State Park on Long Island, has been family owned and operated . (Recording No. They were able to ride the horses, groom a pony and even give the horses a bath. Portions of Freshwater Wetland BW-1 and its regulated adjacent area are located on the site of the Babylon Riding Center. 19]). When skeptics tell us the horse is doing all the work, we just smile because we know better. Furthermore, the Commissioner should conclude that based on the proof adduced at the administrative enforcement hearing, Babylon Riding Center violated various provisions of ECL article 24 (Freshwater Wetlands) and implementing regulations, as well as ECL article 17 (State Pollutant Discharge Elimination System [SPDES] Permits) and implementing regulations, as alleged in the March 12, 2021, complaint. 934 . 2) is 27:06 minutes. 8 and 13]; (8) a berm measuring 30 ft by 6 ft [Photo No. The 42-acre Belmont Lake is encircled by a similar path, making a total of 7.6 miles of multi-use trails. Department staff returned to the site on May 1, 2018, and observed a large pile consisting of horse manure and bedding on the site within the boundary of Freshwater Wetland BW-1, and adjacent to the Carlls River. Ancient sources attributed the Garden to King Nebuchadnezzar II in the 6th century BC as a gift to his wife, Amytis. As set forth in the hearing report, respondent failed to file an answer to the complaint served by Department staff in this matter and failed to appear for the adjudicatory hearing that was held on December 17, 2021 (see Hearing Report at 3 [Finding of Fact No. Babylon became a symbol of worldliness and evil. Finally, Department staff provided proof of service of the notice of hearing and complaint upon BRC. Staff testified that no erosion control features or catch basin existed between the manure pile and the Carlls River (see id. The Book of Revelation refers to Babylon many centuries after it ceased to be a major political center. The fill remains in place. (Recording No. 5]; Hearing Exhibit 2, Affidavit of Christina Knoll sworn to December 14, 2021 [Knoll Affidavit] 7). 7 and 16]; (7) a stockpile of topsoil in an area measuring 64 ft by 46 ft [Photos Nos. 8. We are a family orientated facility, that strives to bring fun filled memories for everyone in the family!. Based upon the record before me, including the lack of any SPDES permit and the activities conducted at the site, I conclude that respondent is in violation of ECL 17-0701(1), 17-0803, 17-0501, 17-0505, and 6 NYCRR 750-1.4(a). 15:08- 18:15; see Exhibit 9. This state forest is home to five horseback riding trails that make up almost 20 miles of bridle paths in addition to trails for mountain biking, hiking, and . Respondent must document in writing its reasons for any request for an extension of these dates. Exhibit Chart. Wetland vegetation provides habitat for wildlife, stabilizes the soils, and absorbs excess nutrients before the groundwater enters downstream surface waters. (Recording No. The Hanging Gardens of Babylon is one of the Seven Wonders of the Ancient World. 03/09/2023. [3] On February 28, 2017, Department staff observed the manure pile at this location on the site. We offer horseback riding, trail riding, and riding classes. The area remains cleared. Aerial Photograph of Babylon Riding Center Legend - Location of Photographs taken on February 28, 2017. 14]; and (11) a 15 ft by 30 ft rock pile [Photo No. For these two mailings, Department staff relied on the information on file with the New York State Department of State, Division of Corporations. We are a family orientated facility, that strives to bring fun filled memories for everyone in the family! (Recording No. This class of wetland provides the most critical of the State's wetland benefits (see 6 NYCRR 663.5[e] [description of Class I wetlands]; see also Hearing Report at 3 [Finding of Fact No. 2bd. In the fifth cause of action, staff alleged a violation of ECL article 17 (Water Pollution Control), and implementing provisions of 6 NYCRR part 750 (State Pollutant Discharge Elimination System [SPDES] Permits). Finally, respondent has not cooperated with Department staff to resolve these violations. The first depicts the site on October 26, 2015. The second depicts the site on October 29, 2016, about one year later. Some of the fill observed on the site could introduce pollutants to the wetlands via runoff events. DEPARTMENT OF ENVIRONMENTAL CONSERVATION, In the Matter of the Violations of Articles 17 and 24 of the Upload A Photo Add A Video. Subsequent site visits by Department staff show that the area remains cleared. Click . Our facility offers riding lessons Tuesday - Sunday from 9:00am - 7:00pm, and our facility boasts 2 large outdoor riding rings for the nicer days, as well as an indoor arena for the inclement weather. 1 at 3:00-3:17.). Exhibit 12D is a photograph of a trench located on the side of the manure pile, perpendicular to the Carlls River. Babylon Riding Center is located in West Babylon next to 868-acre Belmont Lake State Park. Reduced concentrations of dissolved oxygen in the waterway will adversely impact trout and other fish, which absorb oxygen from the water for their metabolic processes. Keep your pet happy and entertained all day with some new supplies, such as carriers, from here. 2 at 5:16-6:30; see Exhibit 12D. After you do business with Babylon Riding Center Inc, please leave a review to help other people and improve hubbiz. 1) is 42:24 minutes. You put effort in and eventually become more effective as time goes on. What is the significance of Iraq in the . 499 Winding Rd., Old Bethpage, 516-845-1000,bethpageequestriancenter.com, BIG RIVER BARN RESCUE, INC. (See Recording No. State of New York (6 NYCRR). (Recording No. Official notice (see 6 NYCRR 622.11[a][5]) taken of Daily Precipitation in 2017 at Republic Airport, and Observed Weather in 2017 at Republic Airport, as well as Daily Precipitation in 2018 at Republic Airport, and Observed Weather in 2018 at Republic Airport (Recording No. Staff inspected the site on numerous occasions and observed that conditions have not improved. NY (Recording No. This administrative proceeding concerns allegations by staff of the New York State Department of Environmental Conservation (Department or DEC) that Babylon Riding Center, Inc. (BRC or respondent) violated ECL articles 17 (Water Pollution Control) and 24 (Freshwater Wetlands) and implementing provisions of 6 NYCRR parts 750 (Water Pollution Control) and 663 (Freshwater Wetlands Permit Requirements). Set of 4 Photographs of the Babylon Riding Center taken by B. Lee on May 1, 2018. We offer riding lessons for people of all ages, beginner or advanced. 9, 10, 11, 12; Exhibit 9). We are a family orientated facility, that strives to bring fun filled memories for everyone in the family! The victim's family is now teaming up with an organization called We All Really Matter (WARM) to prevent violence against women of color. Consequently, the violation is ongoing since Department staff's inspection on February 28, 2017. In this matter, the ALJ has comprehensively reviewed the issues relating to respondent's liability in the hearing report (see Hearing Report at 7-10). During the first segment, Kevin A. Jennings testified. This is a good time to break out the boots! We have information on 631-587-7778, including Babylon Riding Center Inc's address and background check reports with criminal records. the staff at the stable were so friendly and the owner, Vinny, was so accommodating! [5] Matter of Linda Wilton and Costello Marine, Inc., Order of the Commissioner, February 1, 1991, at 1 (1991 WL 94068). Department staff commenced the proceeding with service of the March 12, 2021, notice of hearing and complaint upon BRC by certified mail, return receipt requested. For more information, please contact the following: New York State Parks Program: (631) 669-1000; Suffolk County Parks Program: (631) 854-4949; Amityville Village Hall: (631) 264-6000; Babylon Village Hall: (631) 669-1500 The Babylon Riding Center in West Babylon offers horsebackriding lessons for beginners. 2 at 16:20-23:27), and an exhibit chart is attached to this hearing report as Appendix A. 3. After you do business with Babylon Riding Center Inc, please leave a review to help other people and improve hubbiz. New footing in all arenas and brand new paddocks! Consequently, the violation is ongoing since Department staff's inspection on February 28, 2017. 2 at 13:21-13:55, 15:40- 15:57.). (Recording No. Brown, 295 A.D.2d 409, 410, 743 N.Y.S.2d 539; Irish v. Deep Hollow Ltd., 251 A.D.2d 293, 671 N.Y.S.2d 1024). Privacy Policy . Last week, Michigan was hit by a monstrous ice storm. According to Department staff, Mr. Pizzirusso said that he would use a front-end loader to scoop up the leachate collected in the trench depicted in Exhibit 12D, and then dump the contents of the front-end loader into the Carlls River.

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