The EAT has held, in the case of United States of America v S Nolan, that the USA had failed properly to consult representatives about the closure of one of its army bases in the UK. The EAT applied the UK Coal Mining case and confirmed that, in circumstances involving the closure of a workplace, TULRCA 1992 requires collective consultation over the reasons for the closure. As the USA had not consulted on the reasons for closing the base and had failed to start its consultation in good time, the tribunal had correctly ordered a 30-day protective award.