The Timeline: 20 Months From Caught to Closed

The distance between the EPA catching Jupiter 120 LLC and any penalty actually being ordered stretched across nearly two years. Here is exactly how that time was spent.

The Non-Financial Ledger

Lead does not announce itself. It has no smell, no color once it’s been painted over, no immediate sting. It accumulates. It settles into carpet fibers and window tracks and the dust that floats when someone drills into a wall or sands down a doorframe. That is what federal law was written to prevent. That is exactly what Jupiter 120 LLC was supposed to be managing at 120 Jupiter Drive in Garland, Texas.

Garland is a working-class city east of Dallas. It is a city where people rent because they cannot buy. The 60-unit complex on Jupiter Drive is the kind of place where families make their home for years because the rent is workable and the school zone is stable enough and moving costs money nobody has. These are not people who can call their property manager and demand to see EPA certification paperwork. They just live there.

The Residential Lead-Based Paint Hazard Reduction Act of 1992 exists because of what we already know lead does to children under six. It attacks the developing nervous system. It reduces IQ. It causes behavioral problems that follow a child through school and into adulthood. The research is decades old and unambiguous. Congress wrote a law because of it. The EPA created a certification system because of it. Landlords and renovation firms are required to navigate that system because the consequences of not doing so fall on bodies that cannot protect themselves.

When Jupiter 120 LLC sent workers into that pre-1978 building without a single certified renovator on the job, without documented lead-safe work practices, without post-renovation cleaning verification, the cost of that decision was not absorbed by the company. It was absorbed by whoever was home when the drilling started. It was absorbed by whatever child was crawling on the floor afterward. The settlement document says nothing about those people. There is no line item for testing. There is no order to inform tenants that federal violations occurred in their building. The document that resolves this case does not contain the word “tenant” or “resident” or “child” one single time.

The company will pay $44,316 in four installments. The fine is spread out to make it manageable. A payment plan. For poisoning people’s homes without a license. The residents of Jupiter Drive get nothing from this agreement. Not a notice. Not a test. Not an apology. The only thing the settlement requires of Jupiter 120 LLC is that they now follow the rules they were always required to follow.

Legal Receipts: What They Signed

The following are direct quotations from the Consent Agreement and Final Order, Docket No. TSCA-06-2025-6175. These are the words both Jupiter 120 LLC and the EPA agreed to put their names on.

“Respondent had not applied to the EPA nor obtained certification pursuant to 40 C.F.R. § 745.89 from the EPA prior to performing the renovations at the Properties.”

“Respondent failed to assign a certified renovator to the renovations performed by the firm at the Properties.”

“Respondent failed to prepare and retain records documenting compliance with the requirements of 40 C.F.R. § 745.85 for the renovations performed at the Properties.”

“Respondent: admits the jurisdictional allegations set forth herein; neither admits nor denies the specific factual allegations stated herein.”

How It Was Supposed to Work vs. What Actually Happened

Societal Impact Mapping

Public Health

Lead exposure from renovation dust is one of the most documented and preventable public health threats in American housing. The harm documented or implied by this case is concrete.

• The apartment complex at 120 Jupiter Drive was built before 1978, the year the federal government banned lead-based paint in residential housing. Any building from that era is legally presumed to contain lead-based paint unless tested and proven otherwise. Renovation work in such a building, without lead-safe protocols, creates airborne lead dust and lead-contaminated debris.
• Children under six are the population most at risk. Lead exposure at any level in young children causes neurological damage, reduced IQ, impaired hearing, developmental delays, and behavioral problems. The CDC acknowledges there is no known safe level of lead in blood for children. The families living in these 60 units during renovation were exposed to that risk without their knowledge or consent.
• Post-renovation cleaning verification, one of the skipped steps in this case, exists specifically to confirm that lead dust has been removed from surfaces before residents re-enter their homes. Without it, there is no record and no guarantee that contaminated dust was cleaned. Residents would have no way of knowing whether their floors, windowsills, and countertops were safe.
• The settlement does not include any requirement for Jupiter 120 LLC to conduct blood lead testing for tenants, perform environmental testing of the units, or notify current or former residents that these violations occurred. The public health response to documented violations is, in this case, zero.

Economic Inequality

The residents of a 60-unit apartment complex in a working-class city are not in a position to audit their landlord’s EPA certification status. Economic inequality is the reason these violations happen at all, and the reason their consequences fall hardest on the people who can least afford them.

• Pre-1978 housing stock in the United States is disproportionately located in lower-income neighborhoods. Renters in these buildings have fewer options to leave, less legal leverage to demand remediation, and less knowledge of federal housing regulations than wealthier homeowners in newer construction. Garland, TX fits this pattern precisely.
• The cost of lead exposure is not borne by the landlord. Long-term health costs from childhood lead poisoning, including special education services, medical treatment, lost future earnings, and behavioral intervention, are absorbed by families, schools, and public health systems. The $44,316 fine does not begin to account for those costs if any residents were harmed.
• Jupiter 120 LLC received a payment plan for its fine. Four installments, spread across a year, with interest calculated at the Treasury rate. Renters harmed by their negligence have no comparable structured path to compensation. They would need to independently identify, hire, and afford legal representation to pursue any civil claim, with no admission of wrongdoing from the settlement to anchor that claim.
• The contact address for the company’s representative in the settlement document is 3021 Ridge Rd, Suite A277, Rockwall, TX 75032, a suburb where the median household income is significantly higher than Garland. The people running this company and the people living in their building occupy different economic worlds.

The Numbers: What Was Possible vs. What Was Collected

Federal law authorized a maximum penalty of $48,512 per violation per day. What the EPA actually collected tells a different story.

The “Cost of a Life” Metric

What Now?

Jupiter 120 LLC is now certified and claims compliance. The EPA can still pursue action for any violations outside this settlement. Here is who to contact and what to do if you or someone you know lives in pre-1978 rental housing.

Key Entities in This Case

• Respondent: Jupiter 120 LLC, a Texas-based company conducting business at 120 Jupiter Dr., Garland, TX 75040. Company contact via representative R.G. Spencer, 3021 Ridge Rd, Suite A277, Rockwall, TX 75032; spencer@assetmgttoday.com.
• EPA Enforcement Contact: Stan Lancaster, Enforcement and Compliance Assurance Division, Toxics Enforcement Section, EPA Region 6, 1201 Elm Street, Suite 500, Dallas, TX 75270.
• Regional Judicial Officer: Thomas Rucki, EPA Region 6, who ratified and signed the Final Order on October 21, 2024.
• Docket Number: TSCA-06-2025-6175. Reference this number in any correspondence with EPA Region 6 about this case.

Watchlist: Regulatory Bodies

• EPA Region 6 (Dallas): The primary regulator in this case. They have the authority to inspect, penalize, and pursue further action against Jupiter 120 LLC if new violations occur. File complaints at epa.gov/enforcement/report-environmental-violations.
• EPA’s Lead RRP Program: Responsible for certifying renovation firms and individual renovators nationwide. You can look up whether your landlord or their contractor is certified at cfpub.epa.gov/flpp/pub/index.cfm?do=main.firmSearch.
• Texas Department of State Health Services (DSHS): Administers Texas’s lead programs, including lead investigation services and blood lead testing referrals for children in Texas. Contact them if you suspect lead exposure.
• Consumer Financial Protection Bureau (CFPB): If you believe housing conditions linked to lead violations affected your tenancy, financial harm, or you were subjected to fraudulent disclosures about your unit’s renovation history, the CFPB accepts complaints.
• U.S. Department of Housing and Urban Development (HUD): HUD’s Office of Lead Hazard Control and Healthy Homes oversees lead disclosure requirements for rental housing. File a lead disclosure complaint if your landlord failed to provide the federally required lead disclosure before you signed your lease.

What You Can Do Right Now

• If you live or have lived at 120 Jupiter Dr., Garland, TX: Request a blood lead level test from your doctor for any child under six in your household. Mention the EPA violation case TSCA-06-2025-6175 and the date of inspection, February 14, 2023. Keep records.
• If your rental was built before 1978: Ask your landlord in writing whether their renovation contractor holds current EPA RRP certification. Verify it yourself at the EPA’s online firm search tool. A landlord who cannot provide a certification number is a landlord who may be violating federal law.
• Tenant organizing: Connect with local tenant unions in the Dallas-Garland metro area. Collective tenant action is one of the few tools that creates real leverage over property management companies. Local mutual aid organizations can provide legal referrals, help navigating HUD complaints, and direct support to families impacted by lead exposure.
• Report new violations: If you observe renovation work at a pre-1978 property without proper containment, visible dust controls, or posted certification, report it to EPA Region 6 immediately. Every report that triggers an inspection is a potential protection for whoever lives in that building.