UNITED PARCEL SERVICE - CAELC

United Parcel Service's El Centro, California facility (EPA Registry ID 110065133563) carries zero EPA-recorded violations in the trailing 24 months. Yet a derived penalty exposure of $2.12 million appears against the record, attributed through EPA ECHO's five-year penalty allocation methodology [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That figure is not a local adjudication. It is an allocated share of parent-entity settlements, and the distinction matters for any investor reading the number at face value.

The facility operates under NAICS 49211 (General Freight Trucking, Local) as one node in UPS's integrated ground network — a network that reported $88.7 billion in 2025 revenue and averaged 20.8 million package deliveries per day [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. El Centro sits within a much larger enforcement footprint. The most consequential single action in that footprint is a 2022 nationwide RCRA consent agreement covering 1,160 UPS facilities across 45 states and Puerto Rico [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide].

The derived $2.12 million penalty attribution at El Centro reflects EPA's formula — total_5yr × 24/60 — rather than any discrete local proceeding. Investors should read it as a pro-rata share of parent-entity settlements [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Shareholder pressure on environmental justice performance has escalated alongside that enforcement record. On November 13, 2025, As You Sow filed a proxy resolution requesting a third-party environmental justice audit of UPS, citing regulatory, litigation, and reputational risk exposure [source: https://www.asyousow.org/resolutions/2025/11/13-ups-third-party-environmental-justice-audit]. That filing did not emerge in a vacuum. Riverside County, California prosecutors had already obtained a $1.745 million civil judgment against UPS and affiliates for environmental violations, establishing a California-specific enforcement precedent directly relevant to the El Centro operation [source: https://rivcoda.org/UPS_violation]. Taken together, the parent-level settlement history, the California state judgment, and the formal shareholder resolution define the compliance context within which the El Centro facility currently operates.

EPA ECHO lists one facility associated with the UPS-CAELC record at El Centro, CA (FRS 110065133563), with zero quarters of reported non-compliance in the trailing eight quarters and no active permits of record as of May 4, 2026 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $2.12 million penalty figure is not a standalone El Centro adjudication. It is a pro-rata allocation derived from five-year parent-entity enforcement totals using ECHO's documented 24/60 derivation [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Readers should treat the facility-level figure as an accounting allocation tied to broader UPS settlements rather than a site-specific penalty of record.

Two parent-level enforcement milestones anchor the 24-month compliance narrative. On June 16, 2021, EPA Region 6 announced a consent agreement requiring UPS and TForce Freight to bring 183 facilities across Arkansas, Louisiana, Oklahoma, New Mexico, and Texas into RCRA compliance over a 24-month remediation window, accompanied by a $3.8 million civil penalty [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement]. The formal consent agreement and final order documenting that resolution was published the same month [source: https://www.epa.gov/enforcement/consent-agreement-and-final-order-ups]. Then, on October 19, 2022, EPA escalated the scope considerably — a nationwide settlement resolved hazardous waste violations at 1,160 UPS facilities across 45 states and Puerto Rico, including alleged failures to make land disposal determinations and conduct proper on-site management of hazardous waste [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. The jump from 183 facilities to 1,160 in roughly 16 months signals how broadly EPA mapped the underlying compliance gaps across the UPS network.

On the California state enforcement track — the jurisdiction directly relevant to El Centro — the Riverside County District Attorney's office secured a stipulated judgment ordering UPS and affiliated entities to pay $1.745 million for environmental violations [source: https://rivcoda.org/UPS_violation]. That judgment is the most geographically proximate adjudicated action in the record. In parallel, shareholder engagement on environmental justice intensified: As You Sow filed a proxy resolution dated November 13, 2025 asking the UPS board to commission a third-party environmental justice audit, citing Parnassus Investments research linking unmanaged pollution impacts to heightened regulatory scrutiny, litigation exposure, operational disruptions, and brand risk [source: https://www.asyousow.org/resolutions/2025/11/13-ups-third-party-environmental-justice-audit]. The 2026 operational posture adds a structural variable that reshapes the compliance calculus further. UPS announced it will close 51 parcel distribution centers in 2026 — including 27 additional facilities disclosed in late April 2026 — as part of a network consolidation tied to lower package volumes and a new USPS final-mile agreement signed in December 2025 [source: https://www.freightwaves.com/news/ups-to-close-27-additional-parcel-facilities-in-2026] [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. Facility closures materially change the denominator against which hazardous waste compliance is measured and reshape the environmental justice exposure profile of the remaining network.

Action 1 — EPA Region 6 Consent Agreement and Final Order (June 16, 2021). EPA and UPS/TForce Freight entered a CAFO resolving alleged RCRA hazardous waste violations across 183 facilities in Arkansas, Louisiana, Oklahoma, New Mexico, and Texas. Respondents agreed to a 24-month corrective action schedule and paid a civil penalty of $3.8 million [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement]. The full CAFO document was posted on the EPA enforcement portal [source: https://www.epa.gov/enforcement/consent-agreement-and-final-order-ups].

Action 2 — EPA Nationwide RCRA Settlement (October 19, 2022). EPA announced a consent agreement and final order with UPS resolving hazardous waste violations at 1,160 facilities across 45 states and Puerto Rico. Allegations included failure to make land disposal determinations and improper on-site management of hazardous waste. The settlement required UPS to implement environmental policies intended to prevent future noncompliance [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. The geographic breadth of that order — spanning nearly every U.S. jurisdiction — makes it the defining enforcement event in the five-year window that ECHO's allocation methodology draws upon.

Action 3 — Riverside County District Attorney Civil Judgment (California). UPS and affiliated entities were ordered to pay $1.745 million to resolve state environmental violations prosecuted by the Riverside County DA [source: https://rivcoda.org/UPS_violation]. This is the most geographically proximate adjudicated action to the El Centro operation and the most relevant California state precedent in the record. Imperial County, where El Centro sits, falls within the same Southern California regulatory and prosecutorial environment that produced this judgment.

Action 4 — Derived Facility-Level Allocation at El Centro. ECHO's exporter allocates $2,120,000 in penalty exposure to the El Centro record (FRS 110065133563) over the 24-month window, calculated as total_5yr × (24/60). No discrete quarters of non-compliance are flagged against the facility itself during the trailing eight quarters [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The allocation is a methodological output, not a finding of site-level wrongdoing.

UPS-CAELC, El Centro, CA (FRS 110065133563) — The single facility in this record sits in Imperial County, a region with documented CalEnviroScreen pollution burden scores in the upper quartile statewide. ECHO reports zero quarters with non-compliance in the trailing 24 months and no active permits of record; the $2.12 million allocated penalty is a parent-entity derivation, not a site adjudication [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The EJ index is reported as 0.0 in the ECHO extract, which reflects data absence rather than verified zero exposure. Imperial County's demographic and environmental burden profile means that data absence should not be read as a clean bill of health on community-impact metrics.

UPS-affiliated network peer: UNITED PARCEL SERVICE INC (UPS) — 11 facilities, 8 quarters with non-compliance in the trailing 24 months, $10.64 million derived penalty total [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. This is the highest-enforcement-exposure UPS entity record in the NAICS 492110 peer set. At roughly $967,000 per facility, it provides a useful denominator for contextualizing the El Centro single-site allocation.

UPS-affiliated network peer: UNITED PARCEL SERVICES — 10 facilities, 6 quarters with non-compliance, $6.42 million derived penalty total [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Six quarters of flagged non-compliance across a 10-facility footprint indicates a pattern that extends well beyond any single site.

UPS-affiliated network peer: UNITED PARCEL SVC — 16 facilities, 6 quarters with non-compliance, $5.76 million derived penalty total, NAICS 49211 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The 16-facility count makes this the broadest footprint in the peer set by site count, even as its per-facility derived allocation runs below the El Centro figure.

UPS El Segundo Subregional Parcel Distribution Center (CEQA SCH 1987120911) — A California Notice of Determination was recorded for the final EIR of this Los Angeles County distribution facility [source: https://ceqanet.lci.ca.gov/1987120911/3]. The record predates recent enforcement cycles but establishes the CEQA baseline for UPS's California distribution footprint, which is the regulatory framework governing future El Centro expansions or modifications.

The ECHO top_pollutants array is empty for the El Centro record, consistent with the facility's status as a parcel distribution hub rather than a stationary air or water emissions source under Title V or NPDES [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The pollutant surface for UPS enforcement is therefore dominated by RCRA hazardous waste streams rather than criteria air pollutants. That distinction shapes how analysts should frame community exposure risk at El Centro.

Hazardous waste (RCRA Subtitle C) — The October 2022 nationwide settlement specifically cited failure to make land disposal determinations and improper on-site management of hazardous waste at 1,160 facilities [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. Typical waste streams at parcel hubs include damaged shipments of lithium batteries, aerosols, solvents, and reactive consumer chemicals that trigger generator-status obligations under 40 CFR 262. A single damaged pallet of aerosol cans or a leaking lithium battery shipment can cross the threshold from conditionally exempt small-quantity generator to large-quantity generator status, triggering a materially different compliance burden.

Diesel particulate matter and mobile-source NOx — As a NAICS 49211 local freight operation, the facility's primary community-exposure pathway is diesel exhaust from package cars and feeder trucks. UPS's own 2024 GRI Report identifies alternative-fuel fleet transition as a disclosed priority [source: https://about.ups.com/content/dam/upsstories/images/our-impact/reporting/2024-UPS-GRI-Report.pdf]. Imperial County's San Diego Air Basin classification and the facility's proximity to disadvantaged-community census tracts under California SB 535 criteria elevate the environmental justice relevance of mobile-source emissions beyond what a standard ECHO pollutant screen would capture.

Climate-forcing emissions (Scope 1 aviation and ground fleet) — UPS's 2021 sustainability disclosure committed to 40% alternative fuel in ground operations by 2025, 25% renewable electricity by 2025, 30% sustainable aviation fuel by 2035, and carbon neutrality by 2050 [source: https://about.ups.com/content/dam/upsstories/assets/social-impact/2021-esg-highlights-brochure/en_en_2021SustainabilityBrochure_V15.pdf.pdf]. The 2024 GRI Report is the primary reconciliation document against those targets, and the gap between 2021 commitments and 2024 measured performance is the central disclosure question for climate-focused investors.

Within NAICS 492110/49211, the El Centro UPS-CAELC record — zero quarters of non-compliance, $2.12 million derived penalty allocation across one facility — sits below the three largest UPS-affiliated entity records by violation count. On a per-facility penalty-allocation basis, however, it sits above all three [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The peer UPS INC record carries 8 quarters with non-compliance and a $10.64 million derived penalty total across 11 facilities, or roughly $967,000 per facility. El Centro's single-facility allocation of $2.12 million is materially higher on that per-site basis — more than double the UPS INC per-facility figure. That gap is a function of ECHO's allocation methodology rather than a verified site-level adjudication, and analysts should weight it accordingly [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Still, the per-facility comparison is a useful screen for identifying which nodes in the UPS network carry disproportionate allocated exposure relative to their footprint size.

The UPS 10-K filed February 17, 2026 (accession 0001628280-26-008432) does not excerpt a discrete environmental risk factor in the provided Item 1A passage, but advises that 'The Company routinely posts important information... that may be deemed material to investors on the Company's Investors Relations website' and states that UPS 'do[es] not incorporate the contents of any website into this or any other report we file with the SEC' [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. That carve-out means sustainability commitments published on UPS.com carry no SEC filing weight. The filing confirms 2025 revenue of $88.7 billion, average daily volume of 20.8 million packages, the December 2025 USPS final-mile agreement commencing 2026, and the Frigo-Trans and Andlauer Healthcare Group acquisitions expanding cold-chain operations [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. Each of those structural changes reshapes the company's RCRA generator footprint and fleet emissions profile in ways that will not fully appear in compliance data until future reporting cycles. Cold-chain operations introduce temperature-sensitive pharmaceutical waste streams. The USPS agreement shifts final-mile density patterns across the ground network. Fifty-one facility closures in 2026 — including 27 announced in late April — concentrate volume into fewer sites, potentially elevating per-facility waste generation at the nodes that remain open [source: https://www.freightwaves.com/news/ups-to-close-27-additional-parcel-facilities-in-2026]. El Centro's position within that reconfigured network is not yet determined by public record.