EPA RECEIVED A COMPLAINT FROM A TENANT OF FRANKLIN PIERCE ALLEGING THAT SHE HAD NOT RECEIVED DISCLOSURE OF THE FACT THAT THE APARTMENT SHE RENTED FROM THE SCHOOL CONTAINED LEAD PAINT. EPA INSPECTED AND FOUND OUT THAT THE SCHOOL HAD NOT BEEN PERFORMING REQUIRED LEAD PAINT DISCLOSURE ACTIVITIES WHEN RENTING TO STUDENT TENANTS. EPA CHOSE TO PRE-NEGOTIATE THE CASE BECAUSE IT WAS THOUGHT THAT FRANKLIN PIERCE WOULD BE INTERESTED IN CONDUCTING LEAD-PAINT ABATEMENT IN THEIR STUDENT HOUSING, FOR WHICH WE OFFERED PENALTY MITIGATIO