Phoenix Fire Systems, LLC, d/b/a Basic Fire Protection (Board decision, February 5, 2025)
In re Phoenix Fire Systems, LLC, d/b/a Basic Fire Protection (EAB CAA Appeal No. 25-04C): HFC-import settlement approved
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Plain-English summary
Phoenix Fire Systems, LLC, doing business as Basic Fire Protection, imported approximately 186.4 kilograms of HFC-23 from Canada on October 4, 2022. EPA alleged that Phoenix Fire and the importer of record did not possess or expend the required allowances or receive a non-objection notice for the bulk HFCs. The shipment was transported in five cylinders and was later re-exported after EPA issued a denial recommendation to Customs and Border Protection. Phoenix Fire agreed to settle the alleged 186 violations and pay a $5,430 civil penalty. The EAB ratified the Consent Agreement and ordered compliance.
Decision snapshot
- Cited authorities: American Innovation and Manufacturing Act; 42 U.S.C. §§ 7413, 7602, and 7675; 40 C.F.R. parts 13, 19, 22, and 84
- Outcome: The Consent Agreement was ratified, Phoenix Fire was ordered to comply with its terms, and a $5,430 civil penalty was assessed.
- Key point: A consignee may be treated as an importer for HFC allowance requirements, and each kilogram imported can count as a separate violation under the applicable rule.
Full text (EPA EAB public release)
F I L E D
Feb 05, 2025
Clerk, Environmental Appeals Board
ENVIRONMENTAL APPEALS BOARD INITIALS ________________________
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
)
In re Phoenix Fire Systems, LLC, d/b/a Docket No. CAA-2025-8463
)
Basic Fire Protection )
)
)
)
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: February 5, 2025 ________
Aaron P. Avila
Environmental Appeals Judge
1
The three-member panel ratifying this matter is composed of Environmental Appeals
Judges Aaron P. Avila, Wendy L. Blake, and Mary Kay Lynch.
ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
In re: )
) Docket No. CAA-2025-8463
Phoenix Fire Systems, LLC d/b/a Basic Fire )
Protection )
)
)
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 Phoenix Fire Systems, LLC d/b/a Basic Fire Protection (“Phoenix
Fire”), an Illinois corporation headquartered in Frankfort, Illinois. 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 Consent Agreement and Final Order – Docket No. CAA-2025-8463(“Final Order” or “Order”) ratifying this Consent Agreement (“Consent Agreement” or
“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.
-
The EPA is authorized to enforce the AIM Act and any regulation promulgated
thereunder pursuant to the federal enforcement authorities established by Section 113 of
the CAA, 42 U.S.C. § 7413, as though the AIM Act was expressly included in Title VI of
2 Consent Agreement and Final Order – Docket No. CAA-2025-8463the CAA. 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
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.(c) “Consumption allowances” are “a limited authorization to produce and import
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
3 Consent Agreement and Final Order – Docket No. CAA-2025-8463amount 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.
(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.
4
Consent Agreement and Final Order – Docket No. CAA-2025-8463
15. From January 1, 2022, to September 17, 2023, 40 C.F.R. § 84.5(b)(1) (2022) provided
that “[n]o person may import bulk regulated substances, except by expending, at the time
of the 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 compound HFC-23 is regulated by the AIM Act and has an exchange value of
14,800. 40 C.F.R. Part 84, Appendix A. -
“Each 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 40 C.F.R. § 84.5(b)(2) (2022). -
“Every kilogram of bulk regulated substances imported … constitutes a separate violation
of this subpart.” 40 C.F.R. § 84.5(b)(6) (2022).3 -
Sections 113(a)(3)(A) and 113(d)(1) of the CAA, 42 U.S.C. § 7413(a)(3)(A) 7413(d)(1),
authorizes the Administrator of the EPA to assess a civil administrative penalty of not
1
Effective September 18, 2023, 40 C.F.R. § 84.5(b)(1) was revised to: “[n]o 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 was edited to be found under 40 C.F.R. § 84.5(b)(3) and now states, “Each 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 paragraph paragraphs (b)(1)(ii) through (iv) of this section.” ).” 3 Effective September 18, 2023, this provision was edited to be found under 40 C.F.R. § 84.5(b)(7).
5
Consent Agreement and Final Order – Docket No. CAA-2025-8463
more than $25,000 per day of violation of Title VI of the CAA, or regulations
promulgated thereunder. Pursuant to the Federal Civil Penalties Inflation Adjustment Act
of 1990, Pub. L. 101-410, as amended, and its implementing regulation, the Civil
Monetary Penalty Inflation Adjustment Rule, codified at 40 C.F.R. Part 19, the statutory
maximum civil administrative penalty has subsequently been raised to $57,617 per day of
violation. 40 C.F.R. § 19.4, Table 1.
D. STIPULATED FACTS
-
Phoenix Fire owns and operates a facility that provides sells fire protection systems and
provides fire protection system contract work and is incorporated under the laws of the
State of Illinois. Respondent has its headquarters in Frankfort, Illinois.
-
On or about October 4, 2022, Phoenix Fire was the consignee for an import shipment,
which included approximately 186.4 kg of HFC-23, from Canada under Customs Entry
Number MK8-57482162 (“Subject HFCs”).
-
The importer of record, Ward’s Hydraulic Services, LTD, located at 224 Cayer St #1,
Coquitlam, British Columbia V3K 5B1, Canada, did not possess or expend any
consumption or application-specific allowances, nor did it receive a non-objection notice
from the EPA for the Subject HFCs.
-
Respondent did not possess or expend any allowances when importing the Subject
HFCs, nor did it receive a non-objection notice from the EPA for the Subject HFCs.
-
Using the formula provided by 40 C.F.R. § 84.3, the metric tons of exchange value
equivalent (“MTEVe”) of regulated substances are calculated by multiplying the mass
of the regulated substance in kg by the exchange value of the regulated substance and
dividing the product by 1,000. Under this formula, 186.4 kg of HFC-23 is equivalent to
6 Consent Agreement and Final Order – Docket No. CAA-2025-8463about 2,758.7 MTEVe.
-
The Subject HFCs were transported in five cylinders.
-
Respondent is a “person,” as that term is defined in 40 C.F.R. § 84.3.
-
As consignee for the import of the Subject HFCs, Phoenix Fire was an “importer” of the
Subject HFCs within the meaning of 40 C.F.R. § 84.3.
-
The Subject HFCs are bulk regulated substances as defined above at 40 C.F.R. § 84.3.
-
On or about October 27, 2022, the EPA issued a denial recommendation letter to U.S.
Customs and Border Protection for the Subject HFCs, and the Subject HFCs were re-
exported on or about November 8, 2022.
31. ALLEGED VIOLATIONS OF LAW -
Pursuant to 40 C.F.R. § 84.5(b)(6) (2022), every kilogram of the Subject HFCs imported
on October 4, 2022 constitutes a separate violation of 40 C.F.R. § 84.5(b) (2022).
-
The Subject HFCs imported by Respondent on October 4, 2022 are approximately 186.4
kg, which constitutes 186 violations of 40 C.F.R. § 84.5(b)(1) (2022).
E. 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 Consent Agreement;(b) admits to the stipulated facts stated in Section D of this Consent Agreement;
(c) neither admits nor denies the violations alleged in Section E of this Consent
Agreement;(d) consents to the assessment of a civil penalty as stated below;
7 Consent Agreement and Final Order – Docket No. CAA-2025-8463(e) waives any right to contest the alleged violations of law; and
(f) waives its rights to appeal the Final Order accompanying this Consent Agreement.
-
For the purpose of this proceeding, Respondent:
(a) agrees that this Consent Agreement states a claim upon which relief
may be granted against Respondent;(b) acknowledges that this Consent Agreement constitutes an enforcement action
for purposes of considering Respondent’s compliance history in any subsequent enforcement actions related to the Respondent;(c) waives its right to request a hearing as provided at 40 C.F.R. § 22.15(c), any
right to contest the allegations in this Consent Agreement and Final Order, and its right to appeal this Consent Agreement and Final Order;(d) waives any rights or defenses that Respondent has or may have for this matter
to be resolved in federal court, including but not limited to any right to a jury trial, and waives any right to challenge the lawfulness of the Final Order accompanying this Consent Agreement;(e) consents to personal jurisdiction in any action to enforce this Consent Agreement
or Order, or both in the United States District Court for the District of Columbia; and(f) 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 the Consent Agreement or Final Order, or both, and to seek an additional penalty for noncompliance with the Consent Agreement or Final Order, and agrees that federal law shall govern in any such civil action. 8 Consent Agreement and Final Order – Docket No. CAA-2025-8463(g) acknowledges that this Consent Agreement and attached Final Order will be
available to the public and agree that it does not contain any confidential business information or personally identifiable information.(h) acknowledges that its tax identification number may be used for collecting or
reporting any delinquent monetary obligation arising from this Consent Agreement (see 31 U.S.C. § 7701);(i) certifies that the information it has supplied concerning this matter was at the
time of submission true, accurate, and complete; and(j) acknowledges that there are significant penalties for knowingly submitting
false, fictitious, or fraudulent information, including the possibility of fines and imprisonment (see 18 U.S.C. § 1001). -
Civil Penalty. The civil penalty agreed upon by the Parties for settlement purposes is
$5,430 (the “Assessed Penalty”).
-
Penalty Payment. Respondent agrees to pay the Assessed Penalty to the United States in
the manner specified below:
(a) pay the Assessed Penalty within 30 calendar days of the Effective Date of this
Agreement.(b) pay the Assessed Penalty using any method, or combination of methods,
provided on the following website https://www.epa.gov/financial/additional- instructions-making-payments-epa#Pay.gov.(c) identify each and every payment with Docket No. CAA-2025-8643; and
(d) within 24 hours of payment of the EPA Penalty, email proof of payment to Hallie
Lipsey at [email protected]. “Proof of payment” means, as applicable, a copy 9 Consent Agreement and Final Order – Docket No. CAA-2025-8463of 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 Docket No. CAA-2025-8463. -
Failure to pay the full amount of the penalty assessed under this Consent Agreement may
subject Respondent to a civil action to collect any unpaid portion of the proposed civil
penalty and interest. In order to avoid the assessment of interest, administrative costs, and
late payment penalty in connection with such civil penalty, as described in the following
four paragraphs of this Consent Agreement, Respondent must timely pay the penalty.
-
Interest, Charges, and Penalties on Late Payments. Pursuant to 42 U.S.C. § 7524(c)(6), 31
U.S.C. § 3717, 31 C.F.R. § 901.9, and 40 C.F.R. § 13.11, if Respondent fails to timely
pay any portion of the Assessed Penalty per this Agreement, the entire unpaid balance of
the Assessed Penalty and all accrued interest shall become immediately due and owing,
and the EPA is authorized to recover the following amounts.
(a) Interest. Interest begins to accrue from the Filing Date. If the Assessed Penalty is paid in full within 30 days, interest accrued is waived. If the Assessed Penalty is not paid in full within 30 days, interest will continue to accrue until any unpaid portion of the Assessed Penalty as well as any accrued interest, penalties, and other charges are paid in full. Per 42 U.S.C. § 7524(c)(6), interest will be assessed pursuant to 26 U.S.C. § 6621(a)(2), that is the IRS standard underpayment rate, equal to the Federal short-term rate plus 3 percentage points. (b) Handling Charges. The United States’ enforcement expenses including, but not limited to, attorneys’ fees and costs of collection proceedings. 10 Consent Agreement and Final Order – Docket No. CAA-2025-8463(c) Late Payment Penalty. A 10% quarterly non-payment penalty.
-
Late Penalty Actions. In addition to the amounts described in the prior Paragraph, if
Respondent fails to timely pay any portion of the Assessed Penalty, interest, or other
charges and penalties per this Consent Agreement and attached Final Order, the EPA may
take additional actions. Such actions the EPA may take include, but are not limited to, the
following:
(a) Refer the debt to a credit reporting agency or a collection agency, per 40 C.F.R. §§ 13.13 and 13.14; (b) Collect the debt by administrative offset (i.e., the withholding of money payable by the United States government to, or held by the United States government for, a person to satisfy the debt the person owes the United States government), which includes, but is not limited to, referral to the Internal Revenue Service for offset against income tax refunds, per 40 C.F.R. Part 13, Subparts C and H. (c) Suspend or revoke Respondent’s licenses or other privileges, or 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. (d) Request that the Attorney General bring a civil action in the appropriate district court to recover the full remaining balance of the Assessed Penalty, in addition to interest and the amounts described above, per 42 U.S.C. § 7524(c)(6). In any such action, the validity, amount, and appropriateness of the Assessed Penalty shall not be subject to review. -
Allocation of Payments. Pursuant to 31 C.F.R. § 901.9(f) and 40 C.F.R. § 13.11(d), a
partial payment of debt will be applied first to outstanding handling charges, second to
11 Consent Agreement and Final Order – Docket No. CAA-2025-8463late penalty charges, third to accrued interest, and last to the principal that is the
outstanding Assessed Penalty amount.
-
Tax Treatment of Penalties. Penalties, interest, and other charges paid pursuant to this
Consent Agreement and attached Final Order shall not be deductible for purposes of
federal taxes.
-
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.
-
Except as specified by paragraph 40(b), each party shall bear its own attorney’s fees,
costs, and disbursements incurred in this proceeding.
F. EFFECT OF CONSENT AGREEMENT AND ATTACHED FINAL ORDER
-
In accordance with 40 C.F.R. § 22.18(c), Respondent’s full compliance with this
Consent Agreement shall only resolve Respondent’s liability for federal civil
penalties for the violations alleged in Section E of this Consent Agreement.
-
This Consent Agreement and attached Final Order apply to and are binding upon
the Complainant and the Respondent. Successors and assigns of Respondent are
also bound if they are owned, in whole or in part, directly or indirectly, or
12 Consent Agreement and Final Order – Docket No. CAA-2025-8463otherwise controlled by Respondent. Nothing in the previous sentence adversely
affects any right of the EPA under applicable law to assert successor or assignee
liability against Respondent’s successor or assignee.
-
This Consent Agreement constitutes the entire agreement and understanding of the
Parties andsupersedes any prior agreements or understandings among the Parties with
respect to the subject matter hereof.
-
This Consent Agreement may be signed in any number of counterparts, each of which
will be deemed an original and, when taken together, constitute one agreement; the
counterparts are binding on each of the Parties individually as fully and completely as if
the Parties had signed one single instrument, so that the rights and liabilities of the
Parties will be unaffected by the failure of any of the undersigned to execute any or all
of the counterparts; any signature page and any copy of a signed signature page may be
detached from any counterpart and attached to any other counterpart of this Consent
Agreement.
-
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.
13 Consent Agreement and Final Order – Docket No. CAA-2025-846352. The EPA reserves the right to revoke this Consent Agreement and settlement penalty if
and tothe extent that the EPA finds, after signing this Consent 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.
G. 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.
14 Consent Agreement and Final Order – Docket No. CAA-2025-8463CERTIFICATE OF SERVICE
I certify that copies of the foregoing “Consent Agreement” and “Final Order,” in the
matter of Phoenix Fire Systems, LLC, d/b/a Basic Fire Protection, Docket No. CAA-2025-8463, were sent to the following persons in the manner indicated:
By E-mail:
Hallie Lipsey, 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]
Kirk Humbrecht
Phoenix Fire Systems, LLC, d/b/a Basic Fire Protection
744 Nebraska Street
Frankfort, IL 60423-1701
e-mail: [email protected]
Feb 05, 2025
Dated: ____ ______
Tommie Madison
Clerk of the Board
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