NCLC urged the DC Circuit to hold that the EPA's Unilateral Administrative Orders (UAOs) violate due process. Thousands of UAOs requiring companies to conduct costly environmental remediation are issued each year by the EPA. In this case, the EPA issued an order to General Electric to clean up part of the Hudson River; the project is expected to cost billions of dollars. In its brief, NCLC argued that UAOs violate due process as the EPA offers no preliminary hearings or other effective opportunities for businesses to dispute the UAOs. Without due process, businesses will continue to unfairly incur substantial cleanup costs.