Respondent failed to obtain firm certification as required by 40 C.F.R. Part 745, Subpart E. Respondent?s failures to comply with Subpart E are violations of the Renovation, Repair, and Painting (RRP) Rule. The proposed settlement addresses compliance with the RRP Rule and payment of a civil penalty. With regard to compliance, the Respondent will obtain firm certification as required under the RRP Rule.