A client was prepared to purchase an automobile supplier that was subject to an MDEQ Consent Order, and had recently received a letter of violation for violating the Consent Order. As part of the purchase, a new air use permit and the penalty had to be negotiated. Varnum directed the negotiations, and obtained a nine month compliance plan.

When a delay in the issuance of the air use permit later threatened potential daily penalties, Varnum obtained a court order to prevent any penalties and to allow additional time for the start-up of pollution control equipment. After start-up, Varnum provided compliance counseling through two permit violation incidents, which resulted in one letter of violation but no penalties.