In 2006 and 2007, JCI disclosed violations of the Clean Air Act (CAA) at facilities it had recently acquired under EPAÂs Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations Final Policy Statement (Audit Policy), 65 Fed. Reg. 19618 (April 11, 2000). Specifically, JCI disclosed that the 5 facilities did not have CAA operating permits located in Wichita, Kansas; Norman, Oklahoma; Dixon, Illinois; East York Pennsylvania; and Largo, Florida.
 The major corrective actions occurred at the larger facilities [Wichita, KS and Norman, OK]. Previously these facilities had been using large volumes of high-VOC lubricating oils. JCI instituted equipment and process changes that will significantly reduce its VOC emissions. These changes include the use of low VOC-containing lubricant oil and pre-oiled metal sheets (using the low VOC-containing oil), providing significant environmental and public health benefits by reducing VOC emission. JCI made these process changes in August 2008, and will incorporate the new emission limits in its state operating and Title V permits.
o 240 tpy (or ½ million lbs./yr) of VOC emissions will be reduced at Wichita, KS.
o 70 tpy (or 140,000 lbs./yr.) of VOC emissions will be reduced at Norman, OK.