HVAC Services (Board decision, April 24, 2024)

In re HVAC Services (EAB CAA Appeal No. 24-05C): bulk HFC import settlement approved

Decision type

Board decision

Docket

CAA 24-05C

Decided

April 24, 2024

Outcome

Settled

Precedential status

Citable Board precedent

Checked against source

2026-08-21

Official source

Read the official release (epa.gov)

PDF

View Official PDF

Apply this precedent to your situation

This is citable Board precedent from 2024, and it may have been appealed since. Ezel checks how it stands today and answers your situation, with citations.

Final EAB decision

This Environmental Appeals Board Final Order is a final disposition of the enforcement proceeding. The Board ratified the Consent Agreement, ordered HVAC Services to comply with its terms, and approved a $77,679 civil penalty. The full text below is the official EPA release.

About this page: The plain-English summary and decision snapshot below were written by Ezel based on the official EPA EAB release. The full text is the agency's own release.

Read the official release (epa.gov)

Plain-English summary

HVAC Services provides heating and air conditioning services in Mission, Texas. EPA alleged that the company imported R-410A, R-407C, and R-404A from Mexico in April and May 2022 without expending the required allowances. The shipments totaled 10,920 kilograms of HFCs and entered the United States at Progreso, Texas before being sold to a U.S. entity. The Consent Agreement resolved the matter without adjudicating the allegations and approved a $77,679 civil penalty.

Decision snapshot

Cited authorities: The AIM Act and Clean Air Act, 42 U.S.C. §§ 7413 and 7675, with implementing regulations in 40 C.F.R. parts 13, 19, 22, and 84
Outcome: The Consent Agreement was ratified, HVAC Services was ordered to comply with its terms, and a $77,679 civil penalty was approved.
Key point: Importers of bulk regulated HFCs must expend the required allowances when importing them.

Full text (EPA EAB public release)

                                                                                  F I L E D
                                                                                      Apr 24, 2024
                                                                                 Clerk, Environmental Appeals Board
                                                                                 INITIALS ________________________
                 ENVIRONMENTAL APPEALS BOARD
        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C.

                                           )
                                           )

In re HVAC Services ) Docket No. CAA-2024-008449
)
)
)
)

                                   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: April 24, 2024 ________
Mary Kay Lynch
Environmental Appeals Judge

   1
    The three-member panel ratifying this matter is composed of Environmental Appeals

Judges Wendy L. Blake, Mary Kay Lynch, and Ammie Roseman-Orr.
ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.

                                                  )
 In re:                                           )
                                                  )    Docket No. CAA-2024-008449
 HVAC Services                                    )
                                                  )
                                                  )
                                                  )


                                  CONSENT AGREEMENT

                             A. PRELIMINARY STATEMENT

This is an administrative penalty assessment proceeding brought for alleged violations of

  the American Innovation and Manufacturing Act of 2020 (“AIM Act”), 42 U.S.C.

  § 7675, which governs the import of bulk hydrofluorocarbons (“HFCs”), under Section

  113(d) of the Clean Air Act (the “Act” or “CAA”), 42 U.S.C. § 7413(d), which

  authorizes the EPA to bring administrative civil enforcement actions.

HFCs are potent greenhouse gases that accelerate climate change. The United States has

  committed, as a signatory of the Kigali Amendment to the Montreal Protocol, to reduce

  its production and consumption of HFCs by 85% in a stepwise manner by the year 2036.

Complainant is Mary E. Greene, Director, Air Enforcement Division, of the United States
```
  Environmental Protection Agency.
```

Respondent is HVAC Services, a Texas corporation headquartered in Mission, Texas.

  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 Agreement (“Consent Agreement” or

                    Consent Agreement and Final Order, Docket CAA-2024-008449

“Agreement”) 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 of Practice Governing the

Administrative Assessment of Civil Penalties and the Revocation/Termination or

Suspension of Permits, 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
```
This proceeding arises under the AIM Act, 42 U.S.C. § 7675, and the regulations

promulgated thereunder, which impose limits on HFC production and consumption.
EPA is authorized to enforce the AIM Act and any regulation promulgated thereunder

pursuant to the federal enforcement authorities established by Section 113(a) of the CAA,

42 U.S.C. § 7413(a). 42 U.S.C. § 7675(k)(1)(C).

The regulations at 40 C.F.R. Part 84, Subpart A, implement the AIM Act requirement to

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               Consent Agreement and Final Order, Docket CAA-2024-008449

phase down HFC production and consumption.

The regulations at 40 C.F.R. Part 84, Subpart A, apply to anyone who imports a regulated

substance. 40 C.F.R. § 84.1(b).

The regulations at 40 C.F.R. Part 84, Subpart A, contain the following definitions:

(a) An “application-specific allowance” is “a limited authorization granted in

     accordance with subsection (e)(4)(B)(iv) of the AIM Act for the production or

     import of a regulated substance for use in the specifically identified applications

     that are listed in that subsection and in accordance with the restrictions contained

     at § 84.5(c).” 40 C.F.R. § 84.3.

(b) “Bulk” is defined as: “[A] regulated substance of any amount that is in a container

     for the transportation or storage of that substance such as cylinders, drums, ISO

     tanks, and small cans. A regulated substance that must first be transferred from a

     container to another container, vessel, or piece of equipment in order to realize its

     intended use is a bulk substance. A regulated substance contained in a

     manufactured product such as an appliance, an aerosol can, or a foam is not a bulk

     substance.” 40 C.F.R. § 84.3.

     regulated substances; however, consumption allowances may be used to produce

     regulated substances only in conjunction with production allowances.” 40 C.F.R.

     § 84.3.

(d) “Exchange value equivalent” (“EVe”) is defined as “the exchange value-weighted

     amount of a regulated substance obtained by multiplying the mass of a regulated

     substance by the exchange value of that substance.” 40 C.F.R. § 84.3.

                                        3

               Consent Agreement and Final Order, Docket CAA-2024-008449

(e) “Import” is defined as “to land on, bring into, or introduce into, or attempt to land

     on, bring into, or introduce into, any place subject to the jurisdiction of the United

     States, regardless of whether that landing, bringing, or introduction constitutes an

     importation within the meaning of the customs laws of the United States.

     Offloading used regulated substances recovered from equipment aboard a marine

     vessel, aircraft, or other aerospace vehicle during servicing is not considered an

     import.” 40 C.F.R. § 84.3.

(f) “Importer” is defined as: “[A]ny person who imports a regulated substance into

     the United States. ‘Importer’ includes the person primarily liable for the payment

     of any duties on the merchandise or an authorized agent acting on his or her

     behalf. The term also includes: (1) [t]he consignee; (2) [t]he importer of record;

     (3) [t]he actual owner; or (4) [t]he transferee, if the right to draw merchandise in a

     bonded warehouse has been transferred.” 40 C.F.R. § 84.3.

(g) “Person” is defined as “any individual or legal entity, including an individual,

     corporation, partnership, association, state, municipality, political subdivision of a

     state, Indian tribe; any agency, department, or instrumentality of the United

     States; and any officer, agent, or employee thereof.” 40 C.F.R. § 84.3.

(h) “Regulated substance” is defined as: “[A] hydrofluorocarbon listed in the table

     contained in subsection (c)(1) of the AIM Act and a substance included as a

     regulated substance by the Administrator under the authority granted in

     subsection (c)(3).” 40 C.F.R. § 84.3.

From January 1, 2022, to September 17, 2023, 40 C.F.R. § 84.5(b)(1) provided that “[n]o

person may import bulk regulated substances, except by expending, at the time of the
```
                                       4

              Consent Agreement and Final Order, Docket CAA-2024-008449
```
import, consumption or application-specific allowances in a quantity equal to the
```
 exchange-value weighted equivalent of the regulated substances imported.” 1
```
A current list of regulated substances, their chemical formulas, and their exchange values
```
 can be found in Appendix A to 40 C.F.R. Part 84. See 40 C.F.R. § 84.3.
```
The HFC blend R-404A contains HFC-143a, HFC-125, and HFC-134a, which are
```
 regulated by the AIM Act. 40 C.F.R. Part 84, Appendix A.
```
The HFC blend R-410A contains HFC-125 and HFC-32, which are regulated by the AIM
```
 Act. 40 C.F.R. Part 84, Appendix A.
```
The HFC blend R-407C contains HFC-32, HFC-125, and HFC-134a, which are regulated
```
 by the AIM Act. 40 C.F.R. Part 84, Appendix A.
```

From January 1, 2022, to September 17, 2023, 40 C.F.R. § 84.5(b)(2) provided that

 “[e]ach person meeting the definition of importer for a particular regulated substance

 import transaction is jointly and severally liable for a violation of paragraph (b)(1) of this

 section, unless they can demonstrate that another party who meets the definition of an

 importer met one of the exceptions set forth in paragraph (b)(1).” 2

“Every kilogram of bulk regulated substances imported … constitutes a separate violation
```
 of this subpart.” 40 C.F.R. § 84.5(b)(6). 3
```

1
Effective September 18, 2023, 40 C.F.R. § 84.5(b)(1) was revised to: “No person may import bulk regulated substances, either as a single component or a multicomponent substance, except . . . [i]f the importer of record possesses at the time they are required to submit reports to EPA pursuant to § 84.31(c)(7), and expends at the time of ship berthing for vessel arrivals, border crossing for land arrivals such as trucks, rails, and autos, and first point of terminus in U.S. jurisdiction for arrivals via air, consumption or application-specific allowances in a quantity equal to the exchange-value weighted equivalent of the regulated substances imported, whether present as a single component or a multicomponent blend.” 2 Effective September 18, 2023, this provision moved to 40 C.F.R. § 84.5(b)(3) and was revised to “[e]ach person meeting the definition of importer for a particular regulated substance import transaction is jointly and severally liable for a violation of paragraph (b)(1) of this section, unless they can demonstrate that the importer of record possessed and expended allowances in accordance with the requirement outlined in paragraph (b)(1)(i) or (v) of this section or another party who meets the definition of an importer met one of the exceptions set forth in paragraphs (b)(1)(ii) through (iv) of this section.” 3 Effective September 18, 2023, this provision moved to 40 C.F.R. § 84.5(b)(7).
5

                          Consent Agreement and Final Order, Docket CAA-2024-008449

D. STIPULATED FACTS

HVAC Services is a company that specializes in heating and air conditioning services
```
and is located at 2430 Christina Avenue in Mission, Texas.
```
On or about April 27, 2022, HVAC Services imported approximately 3,402 kg of R-
```
410A from Mexico under Customs Entry # EST-0144146-9.
```

On or about May 9, 2022, HVAC Services imported approximately 1,009 kg of R-

410A, 1,100 kg of R-407C, and 1,744 kg of R-404A from Mexico under Customs Entry

# EST-0144542-9.

On or about May 17, 2022, HVAC Services imported 2,030 kg of R-410A and 1,635 kg

of R-404A from Mexico under Customs Entry # EST-0144854 (together with the

imports in Paragraphs 23 and 24, the “Subject HFCs”).

HVAC Services’ Importer Number is 82-178514300.
The Subject HFCs entered the United States at Progresso, Texas and were subsequently
```
sold to an entity in the United States.
```
HVAC Services did not possess or expend any allowances when importing the Subject
```
HFCs.
```

Using the formula provided by 40 C.F.R. § 84.3, the EPA calculated the total metric

tons of exchange value equivalents (“MTEVe”) 4 of the Subject HFCs to be

approximately 28,648. 5

The Subject HFCs were transported in cylinders.
Respondent is a “person,” as that term is defined in 40 C.F.R. § 84.3.

4
The EPA calculates metric tons of EVe (MTEVe) by multiplying the mass of the regulated substance in kg by the exchange value of the bulk regulated substance and dividing the product by 1,000. 5 3,379 kg of R-404A is equivalent to approximately 13,251 MTEVe; 6,441 kg of R-410A is equivalent to approximately 13,446 MTEVe; and 1,100 kg of R-407C is equivalent to approximately 1,951 MTEVe.
6

                        Consent Agreement and Final Order, Docket CAA-2024-008449

32. Respondent is an “importer,” as that term is defined in 40 C.F.R. § 84.3.

The Subject HFCs are bulk regulated substances, as defined in 40 C.F.R. § 84.3.
```
                 E. ALLEGED VIOLATIONS OF LAW
```
The EPA alleges that, on or about April 27, May 9, and May 17, 2022, for each of the

10,920 kg of the Subject HFCs, Respondent violated the prohibition on importing bulk

regulated substances into the United States without expending allowances as required by

40 C.F.R. § 84.5(b).
```
                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) neither admits nor denies the violations alleged in Section E;

(d) consents to the assessment of a civil penalty as stated below;

(e) waives any right to contest the alleged violations of law set forth in Section E
```
     of this Consent Agreement; and
```
(f) 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

     purposes of considering Respondent’s compliance history in any subsequent

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              Consent Agreement and Final Order, Docket CAA-2024-008449

enforcement actions related to the Respondent;

     judicial or administrative review that Respondent may have with respect to

     any issue of fact or law set forth in this Agreement, including any right of

     judicial review under 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 civil penalty agreed upon by the Parties for settlement purposes is

$77,679.

Penalty Payment. Respondent agrees to:

(a) Pay the civil penalty of $77,679 (“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

     on the website https://www.epa.gov/financial/additional-instructions-making-

     payments-epa#Pay.gov.

                                        8

               Consent Agreement and Final Order, Docket CAA-2024-008449

and Final Order, No. CAA-2024-008449.

(d) Within 24 hours of payment of the EPA Penalty, send proof of payment via

     electronic mail to Ethan Thompson 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 United

     States 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;

     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

(d) (1) suspend or revoke Respondent’s licenses or other privileges, or (2) suspend

     or disqualify Respondent from doing business with the EPA or engaging in

                                        9

               Consent Agreement and Final Order, Docket CAA-2024-008449

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,

under 18 U.S.C. § 1001.
Except as qualified by Paragraph 39(a), each party shall bear its own attorney’s fees,
```
                                       10

               Consent Agreement and Final Order, Docket CAA-2024-008449
```
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.
Pursuant to 26 U.S.C. § 6050X and 26 C.F.R. § 1.6050X-1, EPA is required to

send to the Internal Revenue Service (“IRS”) annually, a completed IRS Form

1098-F (“Fines, Penalties, and Other Amounts”) with respect to any court order or

settlement agreement (including administrative settlements), that require a payor to

pay an aggregate amount that EPA reasonably believes will be equal to, or in

excess of, $50,000 for the payor’s violation of any law or the investigation or

inquiry into the payor’s potential violation of any law, including amounts paid for

“restitution or remediation of property” or to come “into compliance with a law.”

EPA is further required to furnish a written statement, which provides the same

information provided to the IRS, to each payor (i.e., a copy of IRS Form 1098-F).

Failure to comply with providing IRS Form W-9 or Tax Identification Number

(“TIN”), as described below, may subject Respondent to a penalty, per 26 U.S.C.

§ 6723, 26 U.S.C. § 6724(d)(3), and 26 C.F.R. § 301.6723-1. In order to provide

EPA with sufficient information to enable it to fulfill these obligations, EPA herein

requires, and Respondent herein agrees, that:

(a) Respondent shall complete an IRS Form W-9 (“Request for Taxpayer
```
                                        11

                Consent Agreement and Final Order, Docket CAA-2024-008449
```
Identification Number and Certification”), which is available at
```
     https://www.irs.gov/pub/irs-pdf/fw9.pdf;
```
(b) Respondent shall therein certify that its completed IRS Form W-9 includes
```
     Respondent’s correct TIN or that Respondent has applied and is waiting for

     issuance of a TIN;
```
(c) Respondent shall email its completed Form W-9 to EPA’s Cincinnati Finance
```
     Center at [email protected], within 30 days after the Final Order ratifying

     this Agreement is filed, and EPA recommends encrypting IRS Form W-9 email

     correspondence; and
```
(d) In the event that Respondent has certified in its completed IRS Form W-9 that it
```
     has applied for a TIN and that TIN has not been issued to Respondent within 30

     days after the Effective Date, then Respondent, using the same email address

     identified in the preceding sub-paragraph, shall further:

           i. notify EPA’s Cincinnati Finance Center of this fact, via email,

              within 30 days after the 30 days after the Effective Date of this

              Agreement; and

           ii. provide EPA’s Cincinnati Finance Center with Respondent’s TIN,

              via email, within five (5) days of Respondent’s issuance and

              receipt of the TIN.
```
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
```
                                       12

               Consent Agreement and Final Order, Docket CAA-2024-008449
```
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 $121,275 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 Agreement 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 the EPA’s authority to seek compliance with any applicable laws or

regulations, 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.
```
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                Consent Agreement and Final Order, Docket CAA-2024-008449
```
H. EFFECTIVE DATE
Respondent and Complainant agree to the Environmental Appeals Board’s issuance of

the attached Final Order ratifying the Agreement. The Effective Date of the

Agreement shall be the date of issuance of the Final Order. The EPA will transmit a

copy of the Final Order and ratified Consent Agreement to the Respondent.
```
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              Consent Agreement and Final Order, Docket CAA-2024-008449
```
The foregoing Consent Agreement In the Matter of HVAC Services, Docket No. CAA-2024- 008449, is Hereby Stipulated, Agreed, and Approved.

COMPLAINANT:

                                             Digitally signed by MARY
                              MARY           GREENE

                              GREENE         Date: 2024.03.18
                                             12:01:24 -04'00'
                              ____________________________________________
                              Mary E. Greene
                              Director, Air Enforcement Division
                              Office of Enforcement and Compliance Assurance
                              U.S. Environmental Protection Agency




                Consent Agreement and Final Order, Docket CAA-2024-008449

CERTIFICATE OF SERVICE

   I certify that copies of the foregoing “Consent Agreement” and “Final Order,” in the

matter of HVAC Services, Docket No. CAA-2024-008449, were sent to the following persons in the manner indicated:

By E-mail:

Ethan Thompson
U.S. Environmental Protection Agency
Air Enforcement Division
[email protected]

Ricardo Maldonado
HVAC Services
[email protected]

Adolfo Campero
Unimex Group
[email protected]

        Apr 24, 2024

Dated: ____ ______
Annette Duncan
Administrative Specialist

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