This case arises from violations of the Clean Air Act, 42 U.S.C. 7401 et seq., pertaining to approximately 2,372 oil-fired boilers operated by the Defendant at public school buildings throughout New York City. The U.S. Environmental Protection Agency (EPA) alleges the Defendant failed to comply with the applicable requirements in the National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources, 40 C.F.R Part 63, Subpart JJJJJJ, 63.11193 et seq. (the Boiler Rule). The Boiler Rule violations include notification and reporting violations (failure to submit Initial Notification reports, Notification of Compliance Status reports and annual compliance certifications), and violations of work practice standards (failure to perform required boiler tune-ups and energy assessments to improve boiler operating efficiency). EPA estimates that full compliance with the Boiler Rule will result in significant boiler emission reductions of up to 25 percent, including hazardous air pollutant (HAP) and particulate matter (PM) emissions. To resolve the Boiler Rule violations, EPA seeks a substantial civil penalty and injunctive relief including completion of all required boiler tune-ups, which will improve boiler efficiency and reduce emissions, and completion of the required energy assessments, which could identify additional efficiency improvements. This case also presents a substantial opportunity for additional, localized red