Proposed Consent Decree, Clean Air Act Citizen Suit

In accordance with section 113(g) of the Clean Air Act, as amended (``CAA'' or the ``Act''), notice is hereby given of a proposed consent decree to address a lawsuit filed by the Environmental Integrity Project: Environmental Integrity Project v. McCarthy, No. 1:14-cv-2106 (RC) (D. D.C.). On December 12, 2014, Plaintiff filed a complaint alleging that Gina McCarthy, in her official capacity as Administrator of the United States Environmental Protection Agency (``EPA''), failed to perform a non-discretionary duty to grant or deny within 60 days two petitions submitted by the Environmental Integrity Project on May 19, 2014, requesting that EPA object to two CAA Title V permits issued by the Texas Commission on Environmental Quality (``TCEQ'') to the Shell Chemical Company and the Shell Oil Company authorizing the operation of the Deer Park Chemical Plant and the Deer Park Refinery, respectively, located in Harris County, Texas. The proposed consent decree would establish a deadline of August 21, 2015, for EPA to take such action.