Document LDGErxJBJr1MqVmejgewm9GQ

FILED 25 NOV 24 AM 08:53 REGIONAL HEARING CLERK UNITED STATES ENVIRONMENTAL PROTECTION AGENCY EPAREGION 6 REGION 6 1201 Elm Street, Suite 500 Dallas, Texas 75270 In the Matter of EcoStar Remodeling and Construction, Respondent. Docket No. TSCA-06-2025-6176 CONSENT AGREEMENT AND FINAL ORDER Preliminary Statement The U.S. Environmental Protection Agency, Region 6 ("EPA" or "Complainant"), and EcoStar Remodeling and Construction ("Respondent") have agreed to a settlement of this action before the filing of a complaint, and thus this action is simultaneously commenced and concluded pursuant to Rules 22.13(b) and 22.18(b)(2) of the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties and the Revocation/Termination or Suspension of Permits, 40 C.F.R. 22.13(b) and 22.18(b)(2). Jurisdiction l. This proceeding is an administrative action for the assessment of civil penalties initiated pursuant to Section 16(a) of the Toxic Substances Control Act ("TSCA"), 15 U.S.C. 261S(a). 2. This Consent Agreement and Final Order serves as notice that the EPA has reason to believe that Respondent has violated Section 409 of TSCA, 15 U.S.C. 2689, by failing to comply with the regulatory requirements of 40 C.F.R. Part 745, Subpart E. In the Matter ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6/ 76 Parties 3. Complainant is the Director of Enforcement and Compliance Assurance Division of the EPA, Region 6, as duly delegated by the Administrator of the EPA and the Regional Administrator, EPA, Region 6. 4. Respondent is EcoStar Remodeling & Construction, a company incorporated in the state of California and conducting business in the state of Texas. Statutory and Regulatory Background 5. TSCA was amended with the Residential Lead-Based Paint Hazard Reduction Act of 1992, 42 U.S.C. 4851 to 4856, with the addition of Title IV - Lead Exposure Reduction, Section 401 to 412 of TSCA, 15 U.S.C. 2681 to 2692. One of the stated purposes of the Act is to implement a broad program to reduce lead-based paint hazards in the Nation's housing stock. 42 U.S.C. 4851. 6. Pursuant to Sections 402, 406, and 407 of TSCA, 15 U.S.C. 2682, 2686, and 2687, the EPA promulgated the Lead, Renovation, Repair and Painting {RRP) Rule at 40 C.F.R. Part 745, Subpart E- Residential Property Renovation, to ensure that owners and occupants of target housing and child-occupied facilities receive information on lead-based paint hazards before renovations begin; and individuals and firms performing renovations are certified and following work practice standards during the renovations. 40 C.F.R. 745.80. 7. The requirements set forth in the regulations at 40 C.F.R. Part 745, Subpart E, Residential Property Renovation, apply to all renovations performed for compensation in target Page 2 of 19 In the Matier ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6176 housing and child-occupied facilities, unless otherwise excluded as set forth in 40 C.F.R. 745.82. 8. The regulation at 40 C.F.R. 745.87(a) provides that failure or refusal to comply with any provision of 40 C.F.R. Part 745, Subpart E, is a violation of Section 409 of TSCA, 15 U.S.C. 2689. Section 409 of TSCA, 15 U.S.C. 2689, provides that it shall be unlawful for any person to fail to comply with, inter alia, any provision of 40 C.F.R. Part 745, Subpart E. 9. Section 16(a) of TSCA, 15 U.S.C. 2615(a), as amended, and 40 C.F.R. 745.87(d), authorize a civil penalty of not more t han $37,500 per day for violations of Section 409 of TSCA, 15 U.S.C. 2689. The Debt Collection Improvement Act of 1996, 31 U.S.C. 3701, as amended, and the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, 28 U.S.C. 2461, and implementing regulations at 40 C.F.R. Part 19, increased these statutory maximum penalties to $48,512 for violations that occur after November 2, 2015, and for which_penalties are assessed on or after December 27, 2023. Definitions 10. The regulation at 40 C.F.R. 745.83 defines "person" as any natural or judicial person including any individual, corporation, partnership, or association; any Indian Tribe, State, or political subdivision thereof; any interstate body; and any department, agency, or instrumentality of the Federal Government. 11. The regulation at 40 C.F.R. 745.83 defines "renovation" as the modification of any existing structure, or portion thereof, that results in the disturbance of painted surfaces, unless that activity is performed as part of an abatement as defined by 40 C.F.R. 745.223. The term renovation includes, but is not limited to, the removal, modification, or Page 3 of 19 In the Maller ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6176 repair of painted surfaces or painted components (e.g., modification of painted doors, surface restoration, window repair, surface preparation activity (such as sanding, scraping, or other such activities that may generate paint dust)); the removal of building components (e.g., walls, ceilings, plumbing, windows); weatherization projects (e.g., cutting holes in painted surfaces to install blown-in insulation or to gain access to attics, planning thresholds to install weather stripping); and interim controls that disturb painted surfaces. 12. Section 401(17) of TSCA, 15 U.S.C. 2681(17), defines "target housing" as any housing constructed prior to 1978, except housing for the elderly or persons with disabilities or any zero-bedroom dwelling (unless any child who is less than six years of age resides or is expected to reside in such housing). 13. The regulation at 40 C.F.R. 745.83 defines "firm" as a company, partnership, corporation, sole proprietorship or individual doing business, association, or other business entity; a Federal, State, Tribal, or local government agency; or a nonprofit organization. EPA Findings of Fact and Conclusions of Law 14. Respondent is, and at all times referred to herein was, a "person" as defined by 40 C.F.R. 745.83. 15. Respondent is, and at all times referred to herein was, a "firm" as defined by 40 C.F.R. 745.83. 16. Pursuant to Section 11 of TSCA, 15 U.S.C. 2610, the EPA conducted an inspection on March 27, 2024, to evaluate Respondent's compliance with TSCA and the RRP Rule. Page 4 of 19 In the Maller ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-61 76 17. At the time of the EPA inspection, and at all times referred to herein, Respondent had engaged in "renovations" as defined by 40 C.F.R. 745.83. 18. At the time of the EPA inspection, and at all times referred to herein, Respondent performed "renovations... for compensation" per 40 C.F.R. 745.82(a) at sixty-two (62) properties (the "Properties") that were "target housing" as defined by Section 401(17) of TSCA, 15 U.S.C. 2681(17).1 19. On June 17, 2024, the EPA sent Respondent a Notice of Potential Violation and Opportunity to Confer letter. On July 16, 2024, the EPA responded to the documentation and information received from Respondent as a result of the opportunity to confer and articulated the EPA's position concerning Respondent's compliance with TSCA. 20. As a result of the EPA inspection and additional information obtained by the EPA, Complainant has determined that violations of the RRP Rule and Section 409 of TSCA, 15 U.S.C. 2689, occurred as a result of Respondent's renovation activities at the Properties. EPA Findings of Violation 21. The facts stated in the EPA Findings of Fact and Conclusions of Law above are herein incorporated. 22. Complainant hereby states and alleges that Respondent has violated TSCA and federal regulations promulgated thereunder as follows: Count I - Failure to obtain certification 23. With certain exceptions not relevant here, 40 C.F.R. 745.81(a)(2)(ii) prohibits firms from performing, offering, or claiming to perform renovations without certification from 1 See Appendix A for list of properties. Page 5 of 19 In the Maller ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6176 EPA under 40 C.F.R. 745.89 in target housing or child-occupied facilit ies. Pursuant to 40 C.F.R. 745.89{a),(1), firms that perform renovations for compensation must apply to EPA for certification to perform renovations. 24. Respondent had not applied to the EPA nor obtained certification, pursuant to 40 C.F.R. 745.89, from the EPA prior to performing the renovation at the Properties. 25. Respondent's failure to obtain certification from the EPA prior to performing a renovation in target housing, pursuant to 40 C.F.R. 745.89, is a violation of 40 C.F.R. 745.81(a)(2)(ii) and Section 409 of TSCA, 15 U.S.C. 2689. Count 2 - Failure to assign certified renovator 26. Pursuant to 40 C.F.R. 745.89(d)(2}, firms performing renovations must ensure that a certified renovator is assigned to each renovation performed by t he firm and discharges all the certified renovator responsibilities identified in 40 C.F.R. 745.90. 27. Respondent failed to assign a certified renovator to each of the renovations performed by the firm at the Properties. 28. Respondent's failures to assign a certified renovator to each of the renovations at the Properties are violations of 40 C.F.R. 745.89(d)(2) and Section 409 of TSCA, 15 U.S.C. 2689. Count 3 - Failure to distribute EPA pamphlet 29. Pursuant to 40 C.F.R. 745.84(a)(1), no more than sixty (60) days before beginning renovation activities in any residential dwelling unit of target housing, the firm performing the renovation must provide the owner of the unit with t he EPA pamphlet titled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Page 6 of 19 Schools. In the Maller ofEcoStar Remodeling & Construction Docker No. TSCA -06-2025-6176 30. Respondent failed to provide each owner of the Properties with the EPA pamphlet prior to the beginning of each of t he renovation activities. 31. Respondent's failures to provide the EPA pamphlet to the owners of the Properties prior to the beginning of the renovation activities are violations of 40 C.F.R. 745.84(a)(1) and Section 409 of TSCA, 15 U.S.C. 2689. Count 4 - Failure to retain RRP records 32. Pursuant to 40 C.F.R. 745.86(a), firms performing renovations must retain, and, if requested, make available to EPA, all records necessary to demonstrate compliance with the RRP Rule for a period of 3 years following completion of the renovation. 33. Pursuant to 40 C.F.R. 745.86(b)(6), one of t he records that must be retained for . inspection is documentation of compliance with the requirements of 40 C.F.R. 745.85, including documentation that a certified renovator was assigned to the project, that the certified renovator provided on-the-job training for all workers used on the project, that the certified renovator performed or directed workers who performed all of the tasks described in 40 C.F.R. 745.85(a), and that the certified renovator performed the post-renovation cleaning verification described in 40 C.F.R. 745.85(b). 34. Respondent failed to prepare and retain records documenting compliance with the requirements of 40 C.F.R. 745.85 as required by 40 C.F.R. 745.86(a) and 745.86(b)(6) for each of the) renovations performed at the Properties. 35. Respondent's failures to prepare and retain records documenting compliance with the requirements of 40 C.F.R. 745.85 for each of the renovations at the Properties are Page 7 of 19 In the Maller ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-61 76 violations of 40 C.F.R. 745.86(a) and 745.86(b)(6) and Section 409 of TSCA, 15 U.S.C. 2689. COMPLIANCE ORDER 36. Within six (6) months of the effective date of this Consent Agreement and Final Order, Respondent shall conduct a Lead Safe Audit of its Texas properties. 37. Within six (6) months of the effective date of this Consent Agreement and Final Order, Respondent shall host a webinar encompassing lead safe compliance. Such webinar shall include invitations to real estate managers and real property counsel within Texas and California. 38. Within nine (9) months of the effective date of this Consent Agreement and Final Order, Respondent shall host a seminar for subcontracted lead safe certified installers. 39. Respondent shall provide proof of holding the above audit and training seminar/webinars to Angela Hays, at hays.angela@epa.gov. This proof would include the announcement of the trainings in question, number in attendance, and a self-certification that the Lead Safe Audit was completed by Respondent. CONSENT AGREEMENT 40. For the purpose of this proceeding, as required by 40 C. F.R. 22.18{b)(2}, Respondent: a. admits the jurisdictional allegations set forth herein; b. neither admits nor denies the specific factual allegations stated herein; c. consents to the assessment of a civil penalty, as stated herein; d. consents to the issuance of any specified compliance or corrective action order; Page 8 of 19 In the Maller of EcoSiar Remodeling & Construction Docket No. TSCA-06-2025-61 76 e. consents to any conditions specified herein; f. consents to any stated Permit Action; g. waives any right to contest the allegations set forth herein; and h. waives its rights to appeal the Final Order accompanying this Consent Agreement. 41. Respondent consents to the issuance of this Consent Agreement and Final Order and consents for the purposes of settlement to the payment of the civil penalty specified herein. 42. Respondent and EPA agree to conciliate this matter without the necessity of a formal hearing and to bear their respective costs and attorneys' fees. Penalty Payment 43. Respondent agrees that, in settlement of the claims alleged herein, Respondent shall pay a civil penalty of Sixty-Three Thousand dollars ($63,000.00}, as set forth below. 44. Respondent shall pay the Assessed Penalty using any method, or combination of appropriate methods, as provided on the EPA website: http://www.epa.gov/financial/makepayment. 45. For additional instructions, see: https://www.epa.gov/[inancial/additionalinstructions-making-payments-epa. 46. Respondent shall enter a payment plan to pay the full civil penalty within twelve (12) months of the effective date of the CAFO. Respondent shall coordinate these civil penalty payments with EPA's Cincinnati Finance Office within thirty {30) days after the effective date of the CAFO. Page 9 of 19 In the Matter ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6/76 47. When making a payment, Respondent shall: a. Identify every payment with Respondent's name and the docket number of this Agreement, Docket No. TSCA-06-2025-6176. b. Concurrently with any payment or within 24 hours of any payment, Respondent shall serve proof of such payment to the following person(s): Lorena S. Vaughn Regional Hearing Clerk U.S. Environmental Protection Agency, Region 6 1201 Elm Street, Suite 500 (ORC) Dallas, Texas 75270-2102 vaughn.lorena@epa.gov; and Angela Hays Enforcement and Compliance Assurance Division Toxics Enforcement Section U.S. Environmental Protection Agency, Region 6 1201 Elm Street, Suite 500 (ECDST) Dallas, Texas 75270-2101 hays.angela@epa.gov; and U.S. Environmental Protection Agency Cincinnati Finance Center Via electronic mail to: CINWD_AcctsReceivable@epa.gov 48. "Proof of payment" means, as applicable, a copy of the check, confirmation of credit card or debit card payment, or confirmation of wire or automated clearinghouse transfer, and any other information required to demonstrate that payment has been made according to EPA requirements, in the amount due; and identified with the appropriate docket number and Respondent's name. 49. Respondent understands that its failure to timely pay any portion of the civil penalty may result in the commencement of a civil action in Federal District Court to recover Page JO of 19 In the Matter ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6176 the full remaining balance, along with penalties and accumulated interest. In such case, interest shall begin to accrue on a civil or stipulated penalty from the date of delinquency until such civil or stipulated penalty and any accrued interest are paid in full. 31 C.F.R. 901.9(b)(l). Interest will be assessed at a rate of the United States Treasury Tax and loan rates in accordance with 31 U.S.C. 3717. Additionally, a charge will be assessed to cover the costs of debt collection including processing and handling costs, and a non-payment penalty charge of six percent (6%) per year compounded annually will be assessed on any portion of the debt which remains delinquent more than ninety (90) days after payment is due. 31 U.S.C. 3717(e)(2). 50. Pursuant to 26 U.S.C. 6050X and 26 C.F.R. 1.6050X-l, 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: Page 11 of I9 . In the Matter ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6/76 a. Respondent shall complete an IRS Form W-9 ("Request for Taxpayer Identification Number and Certific~tion"), 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; Respondent shall email its completed Form W-9 to EPA's Cincinnati Finance Center at chalifoux. jessica@epa.gov within 30 days after the Final Order ratifying this Agreement is filed, and EPA recommends encrypting IRS Form W-9 email correspondence; and c. 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 effective date of this Order; and ii. Provide EPA's Cincinnati Finance Center with Respondent's TIN, via email, within five (S) days of Respondent's issuance and receipt of the TIN. Effect of Settlement and Reservation of Rights 51. Full payment of the penalty proposed in this Consent Agreement shall only resolve Respondent's liability for federal civil penalties for the violations alleged herein. Page 12 of 19 In the Matter ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6176 Complainant reserves the right to take any enforcement action with respect to any other violations of TSCA or any other applicable law. 52. The effect of settlement described in the immediately preceding paragraph is conditioned upon the accuracy"of Respondent's representations to the EPA, as memorialized in paragraph directly below. 53. Respondent certifies by the signing of this Consent Agreement that it is presently in compliance with all requirements of TSCA and its implementing regulations. 54. Full payment of the penalty proposed in this Consent Agreement shall not in any case affect the right of the Agency or the United States to pursue appropriate injunctive or other equitable relief or criminal sanctions for any violations of law. This Consent Agreement and Final Order does not waive, extinguish or otherwise affect Respondent's obligation to comply with all applicable provisions of TSCA and regulat ions promulgated thereunder. 55. Complainant reserves the right to enforce the terms and conditions of this Consent Agreement and Final Order. General Provisions 56. By signing this Consent Agreement, the undersigned representative of Respondent certifies that it is fully authorized to execute and enter into the terms and conditions of this Consent Agreement and has the legal capacity to bind the party it represents to this Consent Agreement. 57. By signing this consent agreement, Respondent waives any rights or defenses that Respondent has or may have for this matter to be resolved in federal court, including but Page 13 of 19 In the Matter ofEcoStar Remodeling & Constroction Docket No. TSCA-06-2025-6176 not limited to any right to a jury trial, and waives any right to challenge the lawfulness of the final order accompanying the consent agreement. 58. This Consent Agreement shall not dispose of the proceeding without a final order from the Regional Judicial Officer or Regional Administrator ratifying t~e terms of this Consent Agreement. This Consent Agreement and Final Order shall be effective upon t he filing of the Final Order by the Regional Hearing Clerk for EPA, Region 6. Unless otherwise stated, all time periods stated herein shall be calculated in calendar days from such date. 59. The penalty specified herein shall represent civil penalties assessed by EPA and shall not be deductible for purposes of Federal, State, and local taxes. 60. This Consent Agreement and Final Order shall apply to and be binding upon Respondent and Respondent's agents, successors and/or assigns. Respondent shall ensure that all contractors, employees, consultants, firms, or other persons or entities acting for Respondent with respect to matters included herein comply with the terms of this Consent Agreement and Final Order. 61. The EPA and Respondent agree to the use of electronic signatures for this matter pursuant to 40 C.F.R. 22.6. The EPA and Respondent further agree to electronic service of this Consent Agreement and Final Order by email to t he following: To EPA: sharma.ravi@epa.gov To Respondent: ig@gelbmanlawfirm.com Page 14 of 19 RESPONDENT EcoStar Remodeling and Construction In the Matter ofEcoStar Remodeling & Constrnction Docket No. TSCA-06-2025-6176 -, Date: 11/20/2024 By: Signature igor sklyarsky Igor Sklyarsky owner Title COMPLAINANT U.S. ENVIRONMENTAL PROTECTION AGENCY Date: November 22, 2024 DigitaUy signed by CHERYL SEAGER Date: 2024.11.22 08:36:35 -06'00" . Cheryl T. Seager Director Enforcement and Compliance Assurance Division U.S. EPA, Region 6 Page 15 of 19 In the Maller ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6/76 FINAL ORDER Pursuant to Section 16(a) of TSCA, 15 U.S.C. 2615(a), 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 foregoing Consent Agreement resolving this matter is hereby ratified and incorporated by reference into this Final Order. Respondent is ORDERED to comply with all of the terms of the Consent Agreement. In accordance with 40 C.F.R. 22.31(b), the effective date of the foregoing Consent Agreement and this Final Order is the date on which this Final Order is filed with the Regional Hearing Clerk. This Final Order shall resolve only those causes of action alleged in the Consent Agreement. Nothing in this Final Order shall be construed to waive, extinguish, or otherwise affect Respondent's (or its officers, agents, servants, employees, successors, or assigns) obligation to comply with all applicable federal, state, and local statutes and regulations, including the regulations that were t he subject of this action. IT IS SO ORDERED. Rucki, Thomas Digitally signed by Rucki, Thomas Date: 2024.11.22 16:55:19 -05'00' Thomas Rucki Regional Judicial Officer Date Page 16 of 19 In the Matter ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6/ 76 CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing Consent Agreement and Final Order was delivered to the Regional Hearing Clerk, U.S. EPA, Region 6, 1201 Elm Street, Dallas, Texas 75270-2102, and that a true and correct copy was sent t his day in the following manner to the addressees: Copy via Email to Complainant: sharma.ravi@epa.gov hays.angela@epa.gov Copy via Email to Respondent: ig@gelbmanlawfirm.com Physical copy to Respondent: 13140 Coit Road, Suite #340 Dallas, TX 75240 Signed ![AM/ ~ / Office of Regional Counsel U.S. EPA, Region 6 Page 17 of 19 In the Matter ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6176 APPENDIX A ADDRESSES OF RRP WORK PRE-1978 HOMES 606 WILDGROVE DR GARLAND TX 75041 3301 REDSTONE DR ARLINGTON TX 76001 4004 LATHAM DR PLANO TX 75023 1439 CASA VALE DR DALLAS TX 75218 1208 OSAGE DR RICHARDSON TX 75086 2934 CHESHIRE WAY GRAND PRAIRIE TX 75052 1355 KINGSLEY DR DALLAS TX 75216 1101 MILL RIVER DR GARLAND TX 75043 1351 KINGSLEY DR DALLAS TX 75216 2014 c'HATSWORTH RD CARROLLTON TX 75001 5244 PARKVIEW DR HALTOM CITY TX 76148 3701 CABEZA DE VACA CIR IRVING TX 75062 ~ 3650 FIRESIDE DR FLOWER MOUND TX 75028 13216 RED FERN LN DALLAS TX 75240 2115 GREENWAY ST ARLINIGTON TX 76010 403 MASTERS AVE WYLIE TX '75098 302 EAST 6TH ST DALLAS TX 75203 222 FREDDIE ST DALLAS, TX 75217 401 W LOUELLA DR HURST TX 76054 1808 GROSS RD DALLAS TX 75228 - 806 BELMONT ST ARLINGTON TX 76012 7644 ROYAL LN DALLAS TX 75230 3912 JANRUE CT HALTOM TX 76117 663 WESTHAVED RD COPPELL TX 75019 588 SURF ST LEWISVILLE TX 75067 - 102 SEWELL AVE MIDLOTHIAN TX 76065 1008 HARRIS DR EULESS TX 76039 ~ 108 W PHILLIPS CT GRAND PRAIRIE TX 75051 2806 WHITE GUM LN GARLAND TX 75044 - 7500 WOODFIELD RD FORT WORTH TX 76112 5020 FLAMINGO DR ROWLETT TX 75089 10211 CARRY BACK CIR DALLAS TX 75229 134 LONGACRE LN DALLAS TX 75217 1712 NORTH PLACE PLANO TX 75074 3541 CORK Pl FORT WORTH TX 76116 2909 N HOUSTON ST FORT WORTH TX 76106 2005 OVERGLEN DR PLANO TX 75074 613 WOODCASTLE DR GARLAND TX 75040 3541 CORK PL FORT WORTH TX 76116 6720 KINGHOLLOW DR, DALLAS, TX 75248 5179 NOLAN ST, FORT WORTH, TX76119 1459 E MORPHY ST, FORT WORTH, TX 76104 8605 EDEN VALLEY LN, DALLAS, TX 75217 204 SHADYBROOK DR., DESOTO, TX 75115 2902 GOLDEN MEADOW DR, GARLAND, TX 75044 2511 EOVERTON RD., DALLAS, TX 75216 5700 TRAIL LAKE DR., ARLINGTON, TX 76016. 3817 MARKS PL, FORT WORTH, TX 76116 5725 WALTHAM AVE., FORT WORTH, TX 76133 Page 18 of 19 4006 SWEETBRIAR DR., GARLAND, TX 75042 2425 EVERGREEN DR., PLANO, TX 75075 6036 PARK MANOR DR., DALLAS, TX 75241 4912 STRICKLAND AVE., THE COLONY, TX 75056 509 16TH ST W, IRVING, TX 75060 3302 HEATHERCREST DR., GARLAND, TX 75044 4118 LONGLEAF DR,, GARLAND, TX 75042 2140 BROOKFIELD AVE., DALLAS, TX 75235 1526 ELMWOOD BLVD., DALLAS, TX 75224 214 MARTHA MNR, RICHARDSON, TX 75081 1408 E LOVERS LN., ARLINGTON, TX 76010 1453 MAPLE DR., GARLAND, TX 75042 13833 JANWOOD LN., FARMERS BRANCH, TX 75234 In the Maller ofEcoStar Remodeling & Construction Docket No. TSCA-06-2025-6176 - Page 19 of 19