Nature Gas Import and Export Inc. (Board decision, June 23, 2023)
In re Nature Gas Import and Export Inc. (EAB CAA Appeal No. 23-04C): greenhouse-gas reporting settlement approved
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Plain-English summary
Nature Gas Import and Export Inc., a Wyoming corporation with a registered office in Casper, was an industrial greenhouse-gas supplier subject to EPA's mandatory reporting requirements. EPA alleged that Nature Gas exceeded the 25,000 metric ton carbon-dioxide-equivalent reporting threshold and did not timely report its industrial greenhouse-gas import quantities for calendar years 2019 and 2020. Nature Gas settled the administrative penalty proceeding without adjudication of the issues and agreed to pay an $84,546 civil penalty within 30 calendar days of the order's effective date. The EAB ratified the Consent Agreement and ordered compliance with its terms.
Decision snapshot
- Cited authorities: Clean Air Act Sections 113, 114, and 302, 42 U.S.C. §§ 7413, 7414, and 7602; 40 C.F.R. parts 13, 22, and 98
- Outcome: The Consent Agreement was ratified, Nature Gas was ordered to comply with its terms, and an $84,546 civil penalty was approved.
- Key point: Suppliers that exceed EPA's greenhouse-gas reporting threshold must timely file the required annual reports.
Full text (EPA EAB public release)
F I L E D
Jun 23, 2023
Clerk, Environmental Appeals Board
INITIALS ________________________
ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
)
In re Nature Gas Import and Export Inc. ) Docket No. CAA-HQ-2023-8430
)
)
FINAL ORDER
Pursuant to 40 C.F.R. § 22.18(b)-(c) of EPA’s Consolidated Rules of Practice, the
attached Consent Agreement resolving this matter is incorporated by reference into this Final
Order and is hereby ratified.
The Respondent is ORDERED to comply with all terms of the Consent
Agreement, effective immediately.
So ordered.1
ENVIRONMENTAL APPEALS BOARD
Dated: June 23, 2023
Kathie A. Stein
Environmental Appeals Judge
1
The three-member panel ratifying this matter is composed of Environmental Appeals Judges Aaron P. Avila, Mary
Kay Lynch, and Kathie A. Stein.
ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
In re: )
) Docket No. CAA-HQ-2023-8430
Nature Gas Import and Export Inc. )
)
)
)
CONSENT AGREEMENT
A. PRELIMINARY STATEMENT
-
This is an administrative penalty assessment proceeding brought under Section 113(d) of
the Clean Air Act (the “Act” or “CAA”), 42 U.S.C. § 7413(d), and Sections 22.13 and 22.18 of the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties and the Revocation/Termination or Suspension of Permits (“Consolidated Rules”) as codified at 40 C.F.R. Part 22. -
Complainant is the United States Environmental Protection Agency (“EPA”). On the
EPA’s behalf, Mary E. Greene, Director, Air Enforcement Division, is delegated the authority to settle civil administrative penalty proceedings under Section 113(d) of the Act. -
Respondent is Nature Gas Import and Export Inc. (“Nature Gas”), a Wyoming
corporation with registered office in Casper, Wyoming. Respondent is a “person” as defined in Section 302(e) of the Act, 42 U.S.C. § 7602(e). -
Complainant and Respondent (together, the “Parties”), having agreed that settlement of
this action is in the public interest, consent to the issuance of the attached final order (“Final Order” or “Order”) ratifying this consent settlement agreement (“ConsentAgreement”) before taking testimony and without adjudication of any issues of law or
fact herein, and Respondent agrees to comply with the terms of this Agreement and Final
Order.
B. JURISDICTION -
This Consent Agreement is entered into under Section 113(d) of the Act, as amended,42
U.S.C. § 7413(d), and the Consolidated Rules, 40 C.F.R. Part 22.
-
The EPA and the United States Department of Justice jointly determined that this
matter, although it involves alleged violations that occurred more than one year
before the initiation of this proceeding, is appropriate for an administrative penalty
assessment. 42 U.S.C. § 7413(d).
-
The Environmental Appeals Board is authorized to ratify this Consent Agreement,
which memorializes a settlement between Complainant and Respondent. 40 C.F.R.
§§ 22.4(a) and 22.18(b).
-
The issuance of this Consent Agreement and attached Final Order simultaneously
commences and concludes this proceeding. 40 C.F.R. § 22.13(b).
C. GOVERNING LAW -
Section 114 of the CAA provides the EPA with broad authority to require
information that will inform the EPA’s implementation of various CAA provisions and
programs. 42 U.S.C. § 7414. Under CAA Section 114(a)(1), the EPA may require
emission sources, persons subject to the CAA, manufacturers of emission control or
process equipment, or persons whom the EPA believes may have necessary information,
to monitor and report emissions and to provide such other information as the EPA
2requests for the purposes of carrying out any provision of the CAA (except for a
provision of title II with respect to motor vehicles).
-
Pursuant to this legal authority, the EPA established the mandatory greenhouse gas
reporting requirements, which have been effective since 2010.ௗ40 C.F.R. Part 98.
-
The general provisions for the mandatory greenhouse gas reporting requirements are set
forth in subpart A, 40 C.F.R. §§ 98.1 – § 98.9, and Tables A-1 – A-7.
-
40 C.F.R. §ௗ98.1(a)ௗestablishesௗgreenhouse gasௗreporting requirements for owners and
operators of certain facilities that directly emit greenhouse gases as well as for certain
suppliers. For suppliers, the greenhouse gases reported are the quantity that would be
emitted from combustion or use of the products supplied.ௗ
-
40 C.F.R. §ௗ98.1(b) provides that owners, operators, and suppliers subject to 40 C.F.R.
Part 98 must follow the requirements of subpart A and all applicable subparts, and if a
conflict exists between a provision in subpart A and any other applicable subpart, the
requirements of the applicable subpart shall take precedence.
-
40 C.F.R. § 98.2(a) provides that the greenhouse gas reporting requirements and related
monitoring, recordkeeping, and reporting requirements of subpart A apply to the owners
and operators of any supplier that meets the requirements of paragraph (a)(4) of this
section.
-
40 C.F.R. § 98.2(a)(4) provides that a supplierௗlistedௗin Table A-5 of 40 C.F.R. Part 98,
subpart A, must submit an annual report that covers all applicable products for which
calculation methodologies are provided in the applicable subpart and subpart A.
-
40 C.F.R. Part 98, subpart OO applies to suppliers of industrial greenhouse gases. Table
A-5 of 40 C.F.R. Part 98, subpart A, lists categories of industrial greenhouse gas
3suppliers subject to 40 C.F.R. Part 98, subpart OO, including: producers of industrial
greenhouse gases and importers of industrial greenhouse gases with annual bulk imports
of N2O, fluorinated greenhouse gas, and CO2 that in combination have greenhouse gas
quantities equivalent to 25,000 metric tons CO2e or more. Table A-5 of 40 C.F.R. Part
98, subpart A, also states that suppliers are defined in each applicable subpart.
-
40 C.F.R. § 98.418 provides that all of the terms used in 40 C.F.R. Part 98 subpart OO
have the same meaning given in the Clean Air Act and 40 C.F.R. Part 98 subpart A,
except the terms “isolated intermediate” and “low-concentration constituent,” which are
defined in § 98.418. 40 C.F.R. § 98.418 further provides that if a conflict exists between a
definition provided in subpart OO and a definition provided in subpart A, the definition
in subpart OO shall take precedence for the reporting requirements in subpart OO. Id.
-
40 C.F.R. §ௗ98.6ௗdefines “exporter” as any person, company, or organization of record
that transfers for sale or for other benefit, domestic products from the United States to
another country or to an affiliate in another country, excluding any such transfers on
behalf of the United States military or military purposes including foreign military sales
under the Arms Export Control Act. An exporter is not the entity merely transporting the
domestic products, rather an exporter is the entity deriving the principal benefit from the
transaction.
-
40 C.F.R. §ௗ98.6ௗdefines “importer” as any person, company, or organization of record
that for any reason brings a product into the United States from a foreign country,
excluding introduction into United States jurisdiction exclusively for United States
military purposes. An importer is the person, company, or organization primarily liable
for the payment of any duties on the merchandise or an authorized agent acting on their
4behalf. The term includes, as appropriate: (1) the consignee, (2) the importer of record,
(3) the actual owner, and (4) the transferee, if the right to draw merchandise in a bonded
warehouse has been transferred.
-
40 C.F.R. §ௗ98.6ௗdefines “industrial greenhouse gases” as nitrous oxide or any fluorinated
greenhouse gas.
-
40 C.F.R. §ௗ98.6ௗdefines “operator” as any person who operates or supervises a facility or
supplier.
-
40 C.F.R. §ௗ98.6ௗdefines “owner” as any person who has legal or equitable title to, has a
leasehold interest in, or control of a facility or supplier, except a person whose legal or
equitable title to or leasehold interest in the facility or supplier arises solely because the
person is a limited partner in a partnership that has legal or equitable title to, has a
leasehold interest in, or control of the facility or supplier shall not be considered an
“owner” of the facility or supplier.
-
40 C.F.R. §ௗ98.6ௗdefines “supplier” as a producer, importer, or exporter in any supply
category included in Table A-5 to this subpart, as defined by the corresponding subpart of
this part.
-
40 C.F.R. § 98.410 defines source categories for suppliers of industrial greenhouse gases.
-
40 C.F.R. § 98.410(a) provides that “the industrial gas supplier source category consists
of any facility that produces fluorinated greenhouse gases or nitrous oxide; any bulk
importer of fluorinated greenhouse gases or nitrous oxide; and any bulk exporter of
fluorinated greenhouse gases or nitrous oxide. Starting with reporting year 2018, this
source category also consists of any facility that produces fluorinated heat transfer fluids
5(HTFs); any bulk importer of fluorinated HTFs; any bulk exporter of fluorinated HTFs;
and any facility that destroys fluorinated greenhouse gases or fluorinated HTFs.”
-
40 C.F.R. § 98.411 specifies the applicable reporting threshold for 40 C.F.R. Part 98
subpart OO and requires any supplier of industrial greenhouse gases who meets the
requirements of 40 C.F.R. § 98.410 and 40 C.F.R. § 98.2(a)(4) to report greenhouse gas
emissions pursuant to 40 C.F.R. Part 98 subpart OO (40 C.F.R. § 98.410 – 40 C.F.R. §
98.418).
-
40 C.F.R. § 98.2(f) provides the methodology to calculate industrial greenhouse gas
quantities for comparison to the 25,000 metric ton CO2e per year threshold under
40 C.F.R. § 98.2(a)(4) for importers and exporters of industrial greenhouse gases, and
states that the imported quantities and the exported quantities must be compared
separately to the 25,000 metric ton CO2e per year threshold.
-
40 C.F.R. § 98.2(i) provides that once a supplier is subject to the requirements of 40
C.F.R. Part 98, the supplier must for each year thereafter comply with all requirements of
40 C.F.R. Part 98, including the requirement to submit annual greenhouse gas reports,
even if the supplier does not meet the applicability requirements in 40 C.F.R. § 98.2(a) in
a future year.
-
40 C.F.R. § 98.2(i)(1) – (3) provide limited exceptions to 40 C.F.R. § 98.2(i):
(a) If the reported quantity of greenhouse gases supplied are less than 25,000 metric tons CO2e per year for five consecutive years, then the owner or operator may discontinue reporting, provided that the owner or operator submits a notification to the EPA no later than March 31 of the year immediately following the fifth consecutive year that announces the cessation of reporting that explains the 6reasons for the reduction in quantity of greenhouse gases supplied and the owner
or operator maintains the corresponding records required under § 98.3(g) for
each of the five consecutive years prior to such notification and for three years
following the year that reporting was discontinued. See 40 C.F.R. § 98.2(i)(1).
The owner or operator must resume reporting if the annual quantity of
greenhouse gases supplied in any future calendar year increases to 25,000 metric
tons CO2e per year or more. Id.
(b) If the reported quantity of greenhouse gases supplied are less than 15,000 metric
tons CO2e per year for three consecutive years, then the owner or operator may
discontinue reporting, provided that the owner or operator submits a notification
to the EPA no later than March 31 of the year immediately following the third
consecutive year that announces the cessation of reporting that explains the
reasons for the reduction in the quantity of greenhouse gases supplied and the
owner or operator maintains the corresponding records required under § 98.3(g)
for each of the three consecutive years prior to such notification and for three
years following the year that reporting was discontinued. See 40 C.F.R. §
98.2(i)(2). The owner or operator must resume reporting if the annual quantity
of greenhouse gases supplied in any future calendar year increases to 25,000
metric tons CO2e per year or more. Id.
(c) If the operations of a supplier are changed such that all applicable processes and
operations cease to operate, then the owner or operator may discontinue
complying with this part for the reporting years following the year in which
cessation of such operations occurs, provided that the owner or operator submits
7
a notification to the Administrator that announces the cessation of reporting and
certifies to the closure of all applicable processes and operations no later than
March 31 of the year following such changes. 40 C.F.R. § 98.2(i)(3). Additional
requirements apply in the event of a partial cessation of operation. Id.
-
40 C.F.R. § 98.3(b) requires the owner or operator of suppliers subject to 40 C.F.R. Part
98 to submit annual reports to the EPA no later than March 31 of each calendar year for
greenhouse gas emissions in the previous calendar year, with the exception of the report
for calendar year 2010, which was due no later than September 30, 2011.
-
40 C.F.R. § 98.3(c) specifies the content of each annual report, other than as provided in
40 C.F.R. § 98.3(d) for reporting year 2010, and includes any other data specified in the
“Data reporting requirements” section of each applicable subpart of 40 C.F.R. Part 98.
-
40 C.F.R. § 98.416 provides a list of information, in addition to the information required
by § 98.3(c)(1) – (3) and (5) – (13), that must be included in each annual report.
-
40 C.F.R. § 98.412 requires reporting of greenhouse gas emissions that would result from
the release of the nitrous oxide and each fluorinated greenhouse gas that is produced,
imported, exported, transformed, or destroyed during the calendar year. Starting with
reporting year 2018, this section of the regulations also requires reporting of the
emissions that would result from the release of each fluorinated HTF that is not also a
fluorinated greenhouse gas and produced, imported, exported, transformed, or destroyed
during the calendar year.
-
Except for certain special exceptions for reporting year 2010, 40 C.F.R. § 98.3(e) requires
use of the calculation methodologies specified in the relevant subparts, in preparing the
annual report. “For each source category, you must use the same calculation methodology
8throughout a reporting period unless you provide a written explanation of why a change
in methodology was required.” 40 C.F.R. § 98.3(e).
-
40 C.F.R. § 98.5 requires each annual report to be submitted electronically through the
“Electronic Greenhouse Gas Reporting Tool” (“e-GGRT”). Each report must be
submitted by a designated representative. See 40 C.F.R. § 98.4.
-
Any violation of 40 C.F.R. Part 98 is a violation of the CAA, including Section
114,ௗ42 U.S.C. § 7414. A violationௗincludes butௗis not limited to failure to report
greenhouse gas emissions, failure to collect data needed to calculate greenhouse gas
emissions, failure to continuously monitor and test, failure to retain records needed to
verify the amount of greenhouse gas emissions, and failure to calculate greenhouse gas
emissions following the methodologies specified in this part. Each day of violation
constitutes a separate violation.ௗ40 C.F.R. § 98.8.ௗSeeࣟalsoௗ74 Fed. Reg. 56395 (Oct. 30,
2009).ௗௗ
D. STIPULATED FACTS -
Nature Gas did not submit annual reports of its industrial greenhouse gas import
quantities to the EPA by March 31 of the subsequent year for industrial greenhouse gas
imports in calendar years 2019 through 2020.
-
On June 30, 2021, Nature Gas submitted reports for its industrial greenhouse gas import
quantities during calendar years 2019 through 2020.
-
Based on the reports described in Paragraph 39, Nature Gas imported quantities of
industrial greenhouse gases of 25,000 or more metric tons CO2e per year in calendar
years 2019 through 2020.
9E. ALLEGED VIOLATIONS OF LAW
-
Nature Gas is an industrial greenhouse gas supplier subject to the mandatory greenhouse
gas reporting requirements.
-
Nature Gas’ industrial greenhouse gas import quantities exceeded the mandatory
greenhouse gas reporting threshold of 25,000 metric tons CO2e per year in one or more
calendar years from 2010 to 2020.
-
Nature Gas did not timely report to the EPA its industrial greenhouse gas import
quantities for at least calendar years 2019 through 2020, in violation of 40 C.F.R. Part 98,
subparts A and OO.
F. TERMS OF CONSENT AGREEMENT -
For the purpose of this proceeding, as required by 40 C.F.R. § 22.18(b)(2),
Respondent:
(a) admits that the EPA has jurisdiction over the subject matter alleged in
this Agreement;(b) admits the facts stipulated in Section D;
(c) consents to the assessment of a civil penalty as stated below;
(d) waives any right to contest the alleged violations of law set forth in Section E
of this Consent Agreement; and(e) waives its rights to appeal the Order accompanying this Agreement.
-
For the purpose of this proceeding, Respondent:
(a) agrees that this Agreement states a claim upon which relief may be
granted against Respondent;(b) acknowledges that this Agreement constitutes an enforcement action for
10purposes of considering Respondent’s compliance history in any subsequent
enforcement actions related to the Respondent;(c) waives any and all remedies, claims for relief and otherwise available rights to
judicial or administrative review that Respondent may have with respect to anyissue of fact or law set forth in this Order, including any right of judicial reviewunder Section 307(b)(1) of the Clean Air Act, 42 U.S.C. § 7607(b)(1);(d) consents to personal jurisdiction in any action to enforce this Agreement or
Order, or both, in the United States District Court for the District of Columbia; and(e) waives any rights it may possess at law or in equity to challenge the authority
of the EPA to bring a civil action in a United States District Court to compel compliance with this Agreement or Order, or both, and to seek an additional penalty for noncompliance with this Agreement or Order, and agrees that federal law shall govern in any such civil action. -
Civil Penalty. The EPA: has determined, based on information provided by Respondent and
use of the Economic Benefit (BEN) computer model, that Respondent obtained an economic
benefit below $5,000 as a result of its noncompliance in this matter and the case team has
exercised its discretion not to pursue the economic benefit.
-
Penalty Payment. The civil penalty agreed upon by the Parties for settlement
purposes is $84,546. Respondent agrees to:
(a) Pay the civil penalty of $84,546 (“EPA Penalty”) within 30 calendar days of
the Effective Date of this Agreement.(b) Pay the EPA Penalty using any method, or combination of methods, provided
onthe website https://www.epa.gov/financial/additional-instructions-making- 11payments-epa#Pay.gov.
(c) Identify each and every payment with the docket number of this Agreement
and Final Order, No. CAA-HQ-2023-8430.(d) Within 24 hours of payment of the EPA Penalty, send proof of payment via
electronic mail to Lauren Tozzi at [email protected] and Ryan Didion at [email protected]. “Proof of payment” means, as applicable, a copy of the check, confirmation of credit card or debit card payment, confirmation of wire or automated clearinghouse transfer, and any other information required to demonstrate that payment has been made according to the EPA requirements, in the amount due, and identified with the docket number. -
If Respondent fails to timely pay any portion of the penalty assessed under this
Agreement, the EPA may:
(a) request the Attorney General to bring a civil action in an appropriate district
court to recover: the amount assessed; interest at rates established pursuant to 26 U.S.C. § 6621(a)(2); the United States’ enforcement expenses; and a 10 percent quarterly nonpayment penalty, 42 U.S.C. § 7413(d)(5);(b) refer the debt to a credit reporting agency or a collection agency, 42 U.S.C.
§ 7413(d)(5), 40 C.F.R. §§ 13.13, 13.14, and 13.33;(c) collect the debt by administrative offset (i.e., the withholding of money payable
by the United States to, or held by the United States for, a person to satisfy the debt the person owes the Government), which includes, but is not limited to, referral to the Internal Revenue Service for offset against income tax refunds, 40 C.F.R. Part 13, subparts C and H; and (1) suspend or revoke Respondent’s 12licenses or other privileges, or (2) suspend or disqualify Respondent from doing
business with the EPA or engaging in programs the EPA sponsors or funds, 40 C.F.R. § 13.17. -
By signing this Agreement, Respondent acknowledges that this Agreement and Order,
including identifying information such as name, federal tax ID number, mailing and
e-mail address, will be available to the public when the Agreement and Certificate of
Service are filed and uploaded to a searchable database and agrees that this
Agreement does not contain any confidential business information or other personally
identifiable information.
-
By signing this Agreement, the undersigned representative of Complainant and the
undersigned representative of Respondent each certify that he or she is fully
authorized to execute and enter into the terms and conditions of this Agreement and
has the legal capacity to bind the party he or she represents to this Agreement.
-
By signing this Agreement, Respondent agrees to acceptance of the Complainant’s:
(a) digital or an original signature on this Agreement; and (b) service of the fully
executed Agreement on the Respondent by mail or electronically by e-mail.
Complainant agrees to acceptance of the Respondent’s digital or an original signature
on this Agreement.
-
By signing this Agreement, Respondent certifies that the information it has supplied
concerning this matter was at the time of submission true, accurate, and complete for
each such submission, response, and statement. Respondent acknowledges that there
are significant penalties for submitting false or misleading information, including the
possibility of fines and imprisonment for knowing submission of such information,
13under 18 U.S.C. § 1001.
-
Except as qualified by Paragraph 47(a), each party shall bear its own attorney’s fees,
costs, and disbursements incurred in this proceeding.
G. EFFECT OF CONSENT AGREEMENT AND ATTACHED FINAL ORDER
-
In accordance with 40 C.F.R. § 22.18(c), completion of the terms of this Consent
Agreement and Final Order resolves only Respondent’s liability for federal civil
penalties for the violations listed in Section E of this Agreement.
-
Penalties paid pursuant to this Agreement shall not be deductible for purposes of
federal taxes.
-
This Agreement constitutes the entire agreement and understanding of the Parties and
supersedes any prior agreements or understandings among the Parties with respect to
the subject matter hereof.
-
The terms, conditions, and compliance requirements of this Agreement may not be
modified or amended after it is ratified except upon the written agreement of both
parties, and approval of the Environmental Appeals Board.
-
Any violation of this Order may result in a civil judicial action for an injunction, or civil
penalties of up to $109,024 per day per violation, or both, as provided in Section
113(b)(2) of the Act, 42 U.S.C. § 7413(b)(2), as well as criminal sanctions as provided
in Section 113(c) of the Act, 42 U.S.C. § 7413(c). The EPA may use any information
submitted under this Order in an administrative, civil judicial, or criminal action.
-
Nothing in this Agreement shall relieve Respondent of the duty to comply with all
applicable provisions of the Act and other federal, state, or local laws or statutes, nor
shall it restrict EPA’s authority to seek compliance with any applicable laws or
14regulations, nor shall it be construed to be a ruling on, or determination of, any issue
related to any federal, state, or local permit.
-
Nothing herein shall be construed to limit the power of the EPA to undertake any action
against Respondent or any person in response to conditions that may present an
imminent and substantial endangerment to the public health, welfare, or the
environment.
-
The EPA reserves the right to revoke this Agreement and settlement penalty if and to
the extent that the EPA finds, after signing this Agreement, that any information
provided by Respondent was materially false or inaccurate at the time such information
was provided to the EPA, and the EPA reserves the right to assess and collect any and
all civil penalties for any violation described herein. The EPA shall give Respondent
notice of its intent to revoke, which shall not be effective until received by Respondent
in writing.
H. EFFECTIVE DATE -
Respondent and Complainant agree to the Environmental Appeals Board’s issuance of
the attached Final Order. The EPA will transmit a copy of the Final Order and ratified
Consent Agreement to the Respondent.
15The foregoing Consent Agreement In the Matter of Nature Gas Import and Export Inc.,
Docket No. CAA-HQ-2023-8430, is Hereby Stipulated, Agreed, and Approved.
FOR RESPONDENT:
Digitally signed by: Roy Xiao
Roy Xiao DN: CN = Roy Xiao email = Roy.Xiao@clydeco.
us OU = Azure Users, ARO, US-ATL
Date: 2023.06.12 20:22:36 -04'00' ___6/12/2023
______________________________________
Signature Date
Roy Xiao
Printed Name
President
Title
1611 E 2nd St. Casper WY 82601
Address
82-2883954
Federal Tax Identification Number
16
The foregoing Consent Agreement In the Matter of Nature Gas Import and Export Inc.,
Docket No. CAA-HQ-2023-8430 is Hereby Stipulated, Agreed, and Approved.
FOR COMPLAINANT:
Digitally signed by
MARY MARY GREENE
Date: 2023.06.20
GREENE 14:19:11 -04'00'
___________________________________________
Mary E. Greene
Director, Air Enforcement Division
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
CERTIFICATE OF SERVICE
I certify that copies of the foregoing “Consent Agreement” and “Final Order,” in the
matter of Nature Gas Import and Export Inc., Docket No. CAA-HQ-2023-8430, were sent to
the following persons in the manner indicated:
By Electronic Mail:
Lauren Tozzi, Attorney Advisor
Ryan Didion, Attorney Advisor
Air Enforcement Division
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
e-mail: [email protected]
[email protected]
David M. Williamson
Williamson Law and Policy, PLLC
1001 Connecticut Ave NW, Suite 612
Washington, DC 20036
e-mail: [email protected]
Dated: Jun 23, 2023
Emilio Cortes
Clerk of the Board
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