Contract analysis

I. Executive Summary The purpose of this memorandum is to analyze the federal and Iowa regulatory requirements applicable to Greenfield Agricultural Partners LLC's ("GAP") planned construction of the Muscatine Expansion Facility (the "MEF") and to recommend a comprehensive permitting strategy and timeline for obtaining all required air and water permits necessary to commence construction. This memorandum is intended

II. Project Description A. Facility Overview Greenfield Agricultural Partners LLC is an Iowa limited liability company (Iowa Secretary of State Filing No. 548213; EIN 46-3827194), with its principal offices located at 4200 Prairie Wind Drive, Suite 300, West Des Moines, Iowa 50266. GAP was founded in 2011 by the Halverson family and has grown to become a significant regional participant in the soybean processing and

III. Air Permitting — Prevention of Significant Deterioration (PSD) Construction Permit A. Regulatory Framework The federal Clean Air Act, 42 U.S.C. §§ 7470–7492, establishes the Prevention of Significant Deterioration program as a preconstruction review requirement for new major stationary sources and major modifications of existing major stationary sources located in areas designated as attainment or unclassifiable

IV. Water Permitting — NPDES Individual Permit A. Regulatory Framework The federal Clean Water Act, 33 U.S.C. § 1342, establishes the National Pollutant Discharge Elimination System program, which requires any person who discharges pollutants from a point source into waters of the United States to obtain an NPDES permit. The NPDES permit sets forth effluent limitations and monitoring requirements designed to ensure t

1. Equalization Basin. Incoming process wastewater is collected in an equalization basin that dampens flow and concentration variations in the influent stream, providing a consistent, steady flow to the downstream treatment units. The equalization basin will be sized to accommodate peak flow conditions and will include mixing equipment to prevent settling of solids.

2. Dissolved Air Flotation ("DAF"). The equalized wastewater is routed to a dissolved air flotation unit, which removes oils, greases, and suspended solids from the wastewater stream. The DAF unit operates by dissolving air into the wastewater under pressure and then releasing the air at atmospheric pressure, causing fine bubbles to form that attach to suspended particles and float them to the surface for removal by

3. Three-Cell Aerated Lagoon. Following DAF treatment, the wastewater flows through a three-cell aerated lagoon system with a total surface area of 4.2 acres and an 18-day hydraulic retention time. The aerated lagoon provides biological treatment of the organic matter in the wastewater, reducing BOD₅ and ammonia-nitrogen concentrations through aerobic microbial degradation. The three-cell configuration provides seque

4. UV Disinfection. The treated effluent from the aerated lagoon system passes through an ultraviolet disinfection system to reduce fecal coliform bacteria levels to below the applicable water quality standard for the Class A1 (Primary Contact Recreation) designated use of the receiving water.

5. Discharge to Sweetland Creek via Outfall 001. The fully treated and disinfected effluent is discharged to Sweetland Creek through Outfall 001. The treatment system has been designed to achieve the following proposed effluent limits for Outfall 001, which are anticipated to be consistent with the technology-based and water quality-based effluent limitations that the IDNR will establish in the individual NPDES permi

V. Coordination with Third Parties The permitting process for the MEF requires close coordination among C&H, GAP's internal teams, the retained technical consultants, and the lender and its counsel. This section describes the coordination framework and the respective roles and responsibilities of each party. A. Pinnacle Environmental Consultants Inc. Pinnacle Environmental is responsible for all technical work produc