Respondent Onekey, LLC, is a builder, general contractor, and construction management company. One of Respondent’s projects is the development of 300 residential units and commercial space (worksite) along the Hudson River in Poughkeepsie, New York. In early 2017, Respondent implemented a soil compaction plan on the worksite that had been designed by a soil engineering company under contract with Respondent. The soil compaction plan dictated using a “surcharge,” which was described as a “mountain” of soil at least 15 feet high that spanned and overlapped the footprint of each pre-constructed building, to slowly compact and settle the earth beneath it. (Tr. 248.)