General Motors Company and Ultium Cells LLC (Board decision, November 20, 2023)
In re General Motors Company and Ultium Cells LLC (EAB TSCA 23-04C): TSCA penalty settlement approved
Apply this precedent to your situation
This is citable Board precedent from 2023, and it may have been appealed since. Ezel checks how it stands today and answers your situation, with citations.
Plain-English summary
General Motors Company and Ultium Cells LLC voluntarily disclosed potential violations involving three confidential chemical substances that were imported, processed, used, or distributed before the required TSCA notices and certifications were complete. The Consent Agreement describes alleged violations of TSCA sections 5, 13, and 15, including importing chemicals not on the TSCA Inventory, failing to submit required import certifications, and processing or using existing stocks. The parties settled without adjudication of the factual or legal issues, and agreed to a $654,150 civil penalty for the violations described in Count IV, with additional penalties possible for certain later imports. The agreement also requires controls for water releases, respiratory protection, dermal protection, hazard communication, disposal, recordkeeping, and monthly reporting while EPA completes TSCA section 5(e) consent orders.
Decision snapshot
- Cited authorities: 15 U.S.C. §§ 2604, 2612, 2614, and 2615; 40 C.F.R. §§ 22.18, 707.20, and 720
- Outcome: The Consent Agreement was ratified, the respondents were ordered to comply with its terms, and a $654,150 civil penalty was approved, with additional stipulated penalties addressed in the agreement.
- Key point: A TSCA settlement can combine a civil penalty with interim controls governing the handling of confidential new chemical substances while EPA completes further review.
Full text (EPA EAB public release)
F I L E D
Nov 20, 2023
Clerk, Environmental Appeals Board
ENVIRONMENTAL APPEALS BOARD INITIALS ________________________
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
In re: )
) Docket No. TSCA-HQ-2023-5008
General Motors Company and Ultium Cells
)
LLC
)
)
)
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
November 20, 2023
Dated: ____ ______
Kathie A. Stein
Environmental Appeals Judge
1
The three-member panel ratifying this matter is composed of Environmental Appeals
Judges Wendy L. Blake, Mary Kay Lynch, and Kathie A. Stein. BEFORE THE ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
In the Matter of: )
)
Ultium Cells LLC )
Warren, OH )
And )
General Motors Company ) Docket No. TSCA-HQ-2023-5008 Detroit, MI )
)
Respondents )
_______)
CONSENT AGREEMENT
Complainant, United States Environmental Protection Agency (EPA or Agency), and
Respondents, Ultium Cells LLC and General Motors Company and (Ultium Cells and GM) (collectively, the Parties), having consented to the entry of this Consent Agreement and proposed Final Order before the taking of any testimony and without adjudication of any issues of law or fact, consent to the terms of this Consent Agreement and attached Final Order.
I. PRELIMINARY STATEMENT
-
This civil administrative proceeding for the assessment of penalties pursuant to section 16(a) of
the Toxic Substances Control Act (TSCA), 15 U.S.C. § 2615(a), as amended by the Frank R. Lautenberg Chemical Safety for the 21 st Century Act, Pub. L. No. 114-182, June 22, 2016, 130 Stat. 448, is being simultaneously commenced and concluded pursuant to the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties, Issuance of Compliance or Corrective Action Orders, and the Revocation, Termination or Suspension of Permits (Consolidated Rules of Practice), 40 C.F.R. Part 22. -
On or about February 14, 2023, Respondents voluntarily disclosed to EPA the potential that three
manufactured (imported) chemical substances were not in compliance with TSCA requirements
assistance in making a compliance determination under recent EPA guidance.
Respondents have claimed the identity of the chemicals as confidential business information (CBI). These chemical substances are herein referred to as Chemicals A, B, and C. On March 28, 2023, Respondents submitted a pre-manufacture notice for Chemicals A, B, and C. Since that date, EPA has been working to complete the review as expeditiously as possible. -
The disclosures described in Counts I, II and III have been determined by EPA to satisfy all of
Incentives for Self-Policing: Discovery,
Disclosure, Correction and Prevention of Violations (Audit Policy), 65 Fed. Reg. 19,618 (Apr. 11, 2000). All disclosures that fall within the Audit Policy qualify for a 100% reduction of the
EPA reserves the right to collect any economic benefit that
may have been realized as a result of noncompliance, even where the entity meets all other Policy conditions. -
Due to Ultium Cells subsequent voluntary self-disclosure of potential noncompliance with
TSCA, EPA has further determined that the allegations described in Count IV qualify for reductions applicable under the TSCA Section 5 Enforcement Response Policy, issued August 5, 1988, as amended June 8, 1989, and July 1, 1993 (TSCA ERP). -
To avoid the disruption of orderly business activities and the expense of protracted and costly
litigation, Respondents, for purposes of this proceeding only and as required by 40 C.F.R.
§ 22.18(b)(2):a. admit the following jurisdictional allegations and waives any defenses to jurisdiction:
i. Respondents are corporations located at 300 Renaissance Center, Detroit, MI 48243 (General Motors) and 7400 Tod Ave SW, Warren, OH 44481 (Ultium Cells) and each is 720.3(x) and, as such, is subject to TSCA and its regulations: and ii. Respondent General Motors manufactures (imports) and distributes in commerce, and Respondent Ultium Cells processes, uses, and distributes in commerce, Chemicals A, B, and C, or mixtures containing these chemicals, or in the past Respondent General Motors has manufactured (imported) and distributed in commerce, and Respondent Ultium Cells has processed, used, and distributed in commerce Chemicals A, B, and C, or mixtures containing these chemicals as those terms are defined in sections 3(2), (5), (9), (10), and (13) of TSCA, 15 U.S.C. § 2602(2), (5), (9), (10), and (13) respectively, and 40 C.F.R. § 720.3(e), (i), (q), (u), and (aa). Respondents are subject to TSCA, and the regulations promulgated thereunder.b. neither admit nor deny the specific factual allegations contained herein;
c. consent to the assessment of a civil penalty on the terms discussed below;
d. consent to any conditions specified in this Consent Agreement;
e. waive any right to contest the alleged violations of law set forth herein; and
f. waive the rights to appeal the proposed Final Order accompanying this Consent
Agreement.
II. EPA'S FINDINGS OF FACT AND LAWCOUNT I TSCA § 5(a)(1) VIOLATIONS -
Any chemical substance that is not included in the chemical substance list compiled and
published under section 8(b) ofC.F.R. § 720.3(v).
-
Section 5(a)(l) of TSCA, 15 U.S.C. §2604(a)(1), and 40 C.F.R. §§ 720.22(a)(1) and 720.40(b),
provide that no person may manufacture (import) a new chemical substance unless such person submits a Premanufacture Notice (PMN) to EPA at least ninety (90) calendar days before manufacturing that substance. -
On February 14, 2023, March 2, 2023, March 9, 2023, and March 20, 2023, Respondents
voluntarily provided additional information for their self-disclosures, indicating to EPA that Respondent General Motors had manufactured (imported) Chemicals A, B, and/or C a number of times between November 2021 and March 3, 2023 (with relevant dates and quantities claimed as CBI). -
Chemicals A, B, and C were not included on the TSCA Inventory at the time of import.
U.S.C. § 2602(11), and 40 C.F.R. § 720.3(v).
10.
Chemicals A, B, and/or C for non-exempt commercial purposes constitutes a failure to comply
with section 5 of TSCA, 15 U.S.C. § 2604, which is a prohibited act under section 15(1) of
TSCA, 15 U.S.C. § 2614(1), and may subject an entity to civil penalties pursuant section 16(a) of
TSCA, 15 U.S.C. § 2615(a).
COUNT II TSCA § 13(a)(1)(B) VIOLATIONS
-
Section 13(a)(1)(B) of TSCA, 15 U.S.C. § 2612(a)(1)(B), provides that the Treasury shall refuse
violation of a rule or order under section 5, 15 U.S.C. § 2604. Pursuant to 40 C.F.R.
§ 707.20(b)(2)(i), importers must sign the following statement for each import of a chemicalall applicable rules or orders under TSCA and that I am not offering a chemical substance for
-
On February 14, 2023, March 2, 2023, March 9, 2023, March 20, 2023, Respondents voluntarily
provided additional information for their self-disclosures, indicating to EPA that imports of
Chemicals A, B, and C occurred a number of times between November 2021 and March 3, 2023
(with relevant dates and quantities claimed CBI). -
Failure to submit proper certifications under section 13 of TSCA prior to importing Chemicals
A, B, and C constitutes a failure to comply with section 13 of TSCA, which is a prohibited act
under section 15(3)(B) of TSCA, 15 U.S.C. § 2614(3)(B), and may subject an entity to civil
penalties pursuant to section 16(a) of TSCA, 15 U.S.C. § 2615(a).COUNT III TSCA § 15(2) VIOLATIONS -
Paragraphs 6 and 7 are incorporated and realleged herein.
-
(2) use for commercial
purposes a chemical substance or mixture which such person knew or had reason to know was -
On or about February 14, 2023, March 2, 2023, March 9, 2023, March 20, 2023, Respondents
voluntarily provided additional information for their self-disclosures, indicating to EPA that
Respondent Ultium Cells processed and used existing stocks of the product containing
Chemicals A, B, and C between May 2022 and March 28, 2023 (with dates and quantities
claimed as CBI). -
Respondent Ultium processing and use of existing stocks of Chemicals A, B, and C from
the date of discovery on January 24, 2023, to March 7, 2023, constitutes a violation of TSCA
section 15(2), 15 U.S.C. § 2614(2)), which may subject an entity to civil penalties pursuant to
section 16(a) of TSCA, 15 U.S.C. § 2615(a).COUNT IV TSCA § 15(2) VIOLATIONS -
Paragraphs 14 and 15 are incorporated and realleged herein.
-
On or about March 7, 2023, and as later clarified, Respondents informed EPA that they
continued to process and use Chemicals A, B, and C for at least 20 days after the March 28, 2023
date referenced in paragraph 16 (with dates and quantities claimed as CBI). -
Continued processing and use of Chemicals A, B, and C during the time period referenced in
paragraph 19 constitute violations of TSCA section 15(2), 15 U.S.C. § 2614(2)), which may
subject an entity to civil penalties pursuant to section 16(a) of TSCA, 15 U.S.C. § 2615(a).
III. CIVIL PENALTY -
EPA agrees, based upon the facts and information submitted by Respondents and upon
Respondents certification herein to the veracity of this information, that Respondents have
satisfied all the conditions set forth in the Audit Policy for alleged violations described in Counts
I, II, and III, and thereby qualifies for 100% reduction of the gravity component of the civil
penalty for alleged violations that otherwise would apply to these alleged violations. Alleged
violations listed in Count IV do not qualify for 100% gravity component reduction under the
Audit Policy. -
To avoid the disruption of orderly business activities and the expense of protracted and costly
litigation, both Parties agree that the penalty for alleged violations described in Count IV is
$654,150. The penalty is consistent with the TSCA Section 5 Enforcement Response Policy
(TSCA ERP) (amended July 1, 1993). The TSCA ERP was developed in accordance with the
Guidelines for Assessment of Civil Penalties Under Section 16 of the Toxic Substances Control
Act; PCB Penalty Policy, which sets forth a general penalty assessment policy for TSCA
violations. 45 Fed. Reg. 59,770 (Sept. 10, 1980) (Penalty Policy). The TSCA ERP establishes a
framework for applying the statutory factors to be considered in assessing a civil penalty, i.e.:
violation or violations and, with respect to
the violator, ability to pay, effect on ability to continue to do business, any history of prior such§ 2615(a)(2)(B).
The agreed upon civil penalty in this case reflects: (1) a determination of the gravity-based
penalty (GBP) and (2) adjustments to the GBP, taking into account the statutory factors. -
Not more than thirty (30) calendar days after the effective date of the Final Order, Respondent
shallEither:
-
$654,150 made payable to the order of
the Treasurer of the United States of America, and bearing the case docket number TSCA-HQ-
2023-5008, to the following address:U.S. Environmental Protection Agency Fines and Penalties Cincinnati Finance Center PO Box 979078 St. Louis, MO 63197-9000Or
25. Effect a wire transfer in the amount of $654,150 with the notation and
General Motors Company Civil Penalty Docket No. TSCA-HQ-2023-5008 by using the
following instructions:Federal Reserve Bank of New York ABA = 021030004 Account = 68010727 SWIFT address = FRNYUS33 33 Liberty Street New York, NY 10045 -
Respondents shall forward a copy of the check or documentation of a wire transfer to:
Tony R. Ellis, Case Development Officer Waste and Chemical Enforcement Division (2249A) U.S. Environmental Protection Agency 1200 Pennsylvania Ave., NW (WJCS Bldg. Room No. 2119C) Washington, DC 20460 (202) 564-4167 Or as a PDF attachment in an email to: [email protected] -
Pursuant to 31 U.S.C. § 3717 and 40 C.F.R. § 13.11, unless otherwise prohibited by law, EPA
will assess interest and late payment penalties on debts owed to the United States and a charge to
cover the costs of processing and handling the delinquent claim. Interest on the civil penalty
assessed in this CAFO will begin to accrue thirty (30) days after the effective date and will be
recovered by EPA on any amount of the civil penalty that is not paid by the respective due date.
In accordance with 31 U.S.C. § 3717 and 40 C.F.R. § 13.11, Respondents must pay the following
amounts on any amount overdue:a. Interest. Any unpaid portion of a civil penalty must bear interest at the rate established by the Secretary of the Treasury pursuant to 31 U.S.C. § 3717(a)(1). Interest will therefore begin to accrue on a civil penalty or stipulated penalty if it is not paid by the last date required. Interest will be assessed at the rate of the United States Treasury tax and loan rate in accordance with 40 C.F.R. § 13.11(a). b. Monthly Handling Charge. Respondents must pay a late payment handling charge of FIFTEEN dollars ($15.00) on any late payment, with an additional charge of FIFTEEN dollars ($15.00) for each subsequent thirty (30) day period over which an unpaid balance remains. c. Non-payment Penalty. On any portion of a civil penalty more than ninety (90) days past due, Respondents must pay a non-payment penalty charge of six percent (6%) per annum, which will accrue from the date the penalty payment became due and is not paid. 40 C.F.R. § 13.11(c). This non-payment penalty charge is in addition to charges which accrue or may accrue under subparagraphs (a) and (b).IV. TERMS OF SETTLEMENT
-
only
liability for federal civil penalties for the violations alleged in this Consent Agreement.
29.
to EPA in this matter.
- As a condition of this Agreement, Respondents may import, process, use, and distribute
Chemicals A, B, and C, while EPA and Respondents finalize a TSCA section 5(e) Consent Order
for Chemicals A, B, and C, under the following conditions collectively under Paragraph 30
referred to as the Compliance Plan. The Compliance Plan shall remain in place following the
effective date of the CAFO until the TSCA section 5(e) Consent Order for Chemicals A, B, and
C is issued, unless terminated earlier pursuant to either of the following conditions: (1) EPA
notifies Respondents of determination that Respondents cease import, processing,
distribution
finding that it may be necessary to prevent a potential unreasonable risk of injury to human
health or the environment, or (2) Respondents withdraw their PMNs. The import, processing, use
and distribution must be in accordance with the following
respective activities:a. Terms of Manufacturing (Importing)/Processing/Use of Chemicals A, B, and C i. Respondents may import only ii. For the Ultium facilities located in Warren, OH, Spring Hill, TN and Lansing, MI iii. As a cathode active material for use in the manufacture of battery cells iv. Respondents must process/use in an enclosed process b. No Release to Water. Respondents are prohibited from any release of Chemicals A, B, and C, or any waste stream containing Chemicals A, B, and C into water. i. If for any reason Respondents fail to comply with the release limitations applicable to Chemicals A, B, and C, the Company shall notify EPA, in writing, within 5 days of the release. ii. The notification must include the location of the release, an explanation and description of the reasons for the release, the amount of the release or deviation, all actions taken or to be taken to prevent or minimize the release and future release, and a schedule for implementation of any measures to be taken to prevent or mitigate effects of the release and any future releases. iii. Maintain records documenting establishment and implementation of procedures designed to ensure compliance with any applicable water discharge limit, discharge monitoring requirement, or other requirement related to the release to water of Chemicals A, B, and C. Records may include sampling and laboratory analyses of the discharge, and records related to discharges under the Federal Water Pollution Control Act (commonly known as the Clean Water Act (CWA)) or analogous State law, including location oftreatment facility, permit numbers issued under all federal environmental
statutes, method of treatment, monitoring and release records (including
Discharge Monitoring Reports pursuant to the CWA, and /or additional
information in support to demonstrate compliance.
c. Respiratory Protection
i. Respondents must ensure that each person subject to the potential for
inhalation is provided with, and is required to wear, a National Institute for
Occupational Safety and Health (NIOSH)-certified Combination Particulate
respirator with an Assigned Protection Factor (APF) of at least 1000.
ii. All respirators must be issued, used and maintained according to an
appropriate respiratory protection program in accordance with OSHA and
NIOSH respiratory protection requirements in 29 C.F.R. § 1910.134 and 42
C.F.R. part 84.
iii. Records documenting establishment and implementation of respiratory
protection. Records used to demonstrate compliance under 29 C.F.R. §
1910.1200(e) may be used to satisfy this record keeping obligation if such
records fulfill the requirements of respiratory protection.
d. Dermal Personal Protective Equipment
i. Respondents must ensure that each employee reasonably likely to be dermally
exposed through direct handling or contact with equipment or surfaces
containing or contaminated with Chemicals A, B, and C is provided with, and
is required to wear, personal protective equi
body suits) that provides a barrier to prevent dermal exposure.
ii. PPE must be selected and used in accordance with the Occupational Safety
1910.133, and 1910.138.
iii. Gloves must be replaced at the end of each work shift during which they are
exposed to Chemicals A, B, and C. If permeation testing was used to establish
impermeability, gloves may not be used for longer than for which they were
tested.
iv. Demonstration of Imperviousness. Respondents must demonstrate that the
PPE selected provides an impervious barrier to prevent dermal exposure
during expected duration and conditions of exposure. Respondents may make
this demonstration by any one or a combination of the following:
1. Permeation Testing. PPE must be tested alone and in combination with
other chemical substances in the work area under the expected
conditions of exposure. Permeation testing should be conducted
according to the American Society for Testing and Materials (ASTM)
through Protective Clothing Materials under Conditions of Continuous
as a function of time and documented in accordance with ASTM F739
using the format specified in ASTM F1194-
for Documenting the Results of Chemical Permeation Testing of
2. Manufacturer Specifications. Manufacturer specifications may be used
to establish that the PPE is impervious to Chemicals A, B, and C alone
and in combination with other chemical substances in the work area
under the expected conditions of exposure.
v. Maintain records documenting the determinations that chemical protective
clothing is impervious to Chemicals A, B, and C.
e. Hazard Communication
i. Respondents must establish and implement a hazard communication program
consistent with the requirements in 29 C.F.R § 1910.1200 prior to
manufacturing, processing, using and/or distributing Chemicals A, B, and C.
ii. The following health and environmental hazard and precautionary statements
must be included as part of the hazard communication program, appear on
each label, and Safety Data Sheets (SDS), if applicable.
1. Carcinogenicity
2. Specific Target Organ Toxicity: lungs, kidneys, and spleen
iii. Respondents must maintain records documenting the establishment and
implementation of a hazard communication program, including copies of
labels and safety data sheets.
f. Disposal
i. Waste streams containing Chemicals A, B, and C must be disposed of by
landfill or recycled, reused, or reclaimed and treated in accordance with any
appliable federal regulatory requirements for maintaining solid waste under
the Resource Conservation and Recovery Act, or any analogous State law.
ii. Respondents must maintain records documenting compliance with the
applicable disposal requirements including method of disposal, location of
disposal sites, dates of disposal and volume of Chemicals A, B, and/or C. If
the estimated disposal volume is not known or reasonable ascertainable by
Respondents, records must be maintained that demonstrate establishment and
implementation of a program. That ensures compliance with any applicable
disposal requirement(s).
iii. Respondents shall not release to water, as directed in Subpart (b) of this
Paragraph.
- Each Respondent shall maintain records documenting its compliance with its duties under
Paragraph 30 for 5 years after the date they are created and must produce them for inspection,
copying or as otherwise required under Section 11 of TSCA, 15 U.S.C. § 2610.
32. Respondents shall submit a monthly status report on the dates and quantities of imports arriving
in the United States for non-exempt commercial purposes after May 7, 2023 for Chemicals A, B,
and C for each month, a certification statement that the conditions described in paragraph 30 are
Exchange on the fifth business day of each month until EPA finalizes the TSCA section 5(e) Consent Orders for Chemicals A, B, and C, and Respondents submit Notice of Commencement pursuant to 40 CFR Section 720.102.
-
As set forth in this paragraph and Paragraph 34 below, Respondents shall pay certain penalties
negotiated and agreed to by EPA and Respondents for imports of Chemicals A, B, and C arriving
in the United States for non-exempt commercial purposes on or after May 7, 2023 and before
EPA finalizes the TSCA section 5(e) Consent Orders for Chemicals A, B, and C, and
Respondents submit Notice of Commencement pursuant to 40 CFR Section 720.102. Those
importations, including those included , shall be
assessed a $43,610 penalty as a one-day violation for each day of import that occurs containing
Chemicals A, B, and/or C. -
Subsequent to the last monthly status report described in paragraph 32, EPA shall make a written
demand for civil penalties for the importations. Respondents shall pay civil penalties as
described in paragraph 33 above, owing to the United States, not more than thirty (30) calendar
days after receipt of the written demand from EPA. Payment of the penalty amount shall be
made in accordance with the directions described in paragraphs 24-26 above. -
Nothing in this Consent Agreement or the Final Order is intended to, nor shall be construed to,
operate in any way to resolve any criminal liability of Respondents. -
By executing this Consent Agreement, each Respondent certifies that, to the best of its
knowledge regarding the violations alleged herein, and as conditioned in Paragraph 30,
Respondents are in compliance with TSCA sections 5,13, and 15, 15 U.S.C. §§ 2604, 2612 and
2614.V. OTHER MATTERS -
Subject to the terms and conditions herein, this Consent Agreement shall be binding upon the
Parties, and their respective officers, directors, employees, successors, and assigns. The
undersigned representative of each Party certifies that he or she is duly authorized by his or her
respective Party to sign this Consent Agreement. -
This Consent Agreement shall take full effect upon signing and filing of the Final Order by
39. has paid in full the
scheduled civil penalty, paid any stipulated penalties, and submitted documentation required by
the Consent Agreement and Final Order. -
All the terms and conditions of this Consent Agreement together comprise one settlement
agreement, and each of the terms and conditions is in consideration for all the other terms and
conditions. This Consent Agreement shall be null and void if any term or condition of this
Consent Agreement is held invalid or is not executed by all the signatory parties in identical form
or is not approved in such identical form by the EPA Environmental Appeals Board. -
The penalty, including any stipulated penalties specified above, represents civil penalties
assessed by EPA, and shall not be deductible for purposes of federal taxes. -
Respondents to remit the civil penalties provided herein will result in this matter being
forwarded to the United States Department of Justice for collection.
43.
WE AGREE TO THIS:
_____ _______ Gregory Sullivan, Director Catherine Lee, Attorney Waste and Chemical Enforcement Division Waste and Chemical Enforcement Division Office of Civil Enforcement Office of Civil Enforcement Office of Enforcement and Compliance Assurance Office of Enforcement and Compliance United States Environmental Protection Agency Assurance
United States Environmental Protection Agency
Date: ____ 8/15/2023
Date: _____
CERTIFICATE OF SERVICE
I certify that copies of the foregoing “Consent Agreement” and “Final Order,” in the
matter of General Motors Company and Ultium Cells LLC, Docket No. TSCA-HQ-2023-5008, were sent to the following persons in the manner indicated:
By Email:
Cynthia AM Stroman, Partner
King & Spalding LLP, Counsels for GM and Ultium Cells
1700 Pennsylvania Avenue, NW
Suite 900
Washington, DC 20006
Email: [email protected]
Direct Dial: (202) 626-2381
Catherine Lee, Attorney
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance Type text h U.S. Environmental Protection Agency 1200 Pennsylvania Ave., NW Mail Code: 2249A Washington, DC 20460 Email: [email protected] Direct Dial: (202) 564-3172
Nov 20, 2023
Dated: ____ ______
Annette Duncan
Administrative Specialist
Does this precedent still control your case?
Ezel checks whether it still stands, including any court review since, and applies it to your situation with citations.
Opens in Ezel Pro.
- Checks the law as it stands today, not only this page
- Cites every source it relies on, so you can verify it
- Chat, drafting and research in one workspace