WQ0035784_PC-2021-0028_20210809

Parker Poe
Fern A. Paterson
Partner
t: 704.335.9891
f: 704.335.4456
[e-mail]
August 9, 2021
Via Certified Mail
Nathaniel Thornburg
NC DEQ / DWR / ND Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Atlanta, GA
Charleston, SC
Charlotte, NC
Columbia, SC
Greenville, SC
Raleigh, NC
Spartanburg, SC
Washington, DC
Re: Remission Request (Case No.: PC-2021-0028)
Wallace Loft, LLC; The Cottages of Boone - Wastewater Irrigation System
Permit No. WQ0035784; Watauga County
Dear Mr. Thornburg:
By way of this letter, we respectfully seek a reduction in the proposed civil penalty of
$38,541.11 in the above -referenced case on behalf of our client, Wallace Loft, LLC ("Wallace
Loft"), which owns and operates The Cottages of Boone ("The Cottages"). Specifically, Wallace
Lofts requests a reduction in the civil penalty on the grounds that: (1) Wallace Lofts has taken
additional actions, beyond the actions described in the Wallace Loft's response to the Notice of
Violation dated May 20, 2021 (the "Response") to prevent future occurrences, as described further
below; (2) Wallace Loft is in the process of evaluating potential corrective actions at the
wastewater treatment plant ("WWTP"), including the replacement of the existing membranes
serving the two parallel membrane bioreactors; and (3) the release of untreated wastewater was
inadvertent. Various supporting materials are attached to this written remission request, including
the Justification for Remission Request Form and Waiver of Right to an Administrative Hearing
and Stipulation of Facts, which are provided in Attachment A. We genuinely appreciate your
consideration of this written request and the information attached, and request an appropriate
reduction in the civil penalty assessed in this matter.
Wallace Loft Actions to Prevent Future Occurrences — Water Efficiency Measures.
As indicated in its Response, which is attached hereto as Attachment B, Wallace Loft
experienced an approximate doubling of water usage and wastewater inflow rates at The
Cottages during the Coronavirus pandemic, during which daily water usage at The Cottages
approximately doubled from an average to approximately 35,000 gallons/day (GPD) to 75,000
GPD or more. This increased water usage increased the load and demand on the membranes,
and, as wastewater inflows increased, The Cottages also doubled its periodic maintenance
schedule at the membranes from an approximately biweekly to weekly cleaning event.
PPAB 6484251 v1.docx
Parker Poe Adams & Bernstein LLP 620 South Tryon Street Suite 800 Charlotte, NC 28202
t 704.372.9000 f 704.334.4706 www.parkerpoe.com

August 9, 2021
Page 2
Increased wastewater flow rates also complicated the membrane cleaning operations.
During lower flow periods prior to the onset of the pandemic, The Cottages could clean one
membrane train while utilizing the other membrane train to keep up with wastewater influent until
cleaning operations were complete; a process that generally takes approximately 12 hours per
membrane train. At the higher flow rates, one membrane train is not consistently able to keep up
with wastewater inflow during cleaning operations. Wallace Loft therefore began engaging pump
trucks to collect untreated wastewater from the EQ Tank as necessary during planned membrane
cleaning operations, and transport the collected wastewater to the Town of Boone's publicly -
owned treatment works ("POTW").
As explained in the Response, a significant contributing factor to the April 21-23, 2021
bypass was the inability to engage pump trucks on short notice to accommodate an unscheduled
membrane cleaning event, and a stuck 12-inch motor actuated valve that prevented Wallace Loft
from bringing both membrane bioreactors on-line following the completion of the maintenance.
Wallace Loft identified the increased water usage at The Cottages as a root cause of the
increased membrane cleaning and maintenance requirements, and the associated vulnerability
of the WWTP to bypasses when relying upon a single membrane during such activities.
At the time the Response was submitted on May 20, 2021, Wallace Loft had engaged a
consultant, Navitas Equity Solutions ("Navitas"), to evaluate water efficiency measures available
to potentially reduce water usage and wastewater influent rates at The Cottages. Since the
Response was submitted, Wallace Loft engaged Navitas to implement the following water
efficiency measures, as further described in the Navitas proposal provided in Attachment C:
Water Efficiency Measure
Associated Cost
Replace existing toilets with high -efficiency, 0.8
$295,020
gallon/flush toilets
Install high -efficiency, 0.5 gallon/minute aerators in
$14,751
existing bathroom sinks
Install high -efficiency, 1.25 gallon/minute aerators in
$24,585
existing showerheads
Install high -efficiency, 1.0 gallon/minute aerators in
$5,775
existing kitchen sinks
Install in -unit water meters to quickly and efficiently identify
$86,625
and repair potential leaks in residential units
Total Cost:
$426,756
Navitas estimates the proposed water efficiency measures will cumulatively reduce water usage
at The Cottages by greater than 40%. Implementation of the water reduction measures is in
process with a goal of completing implementation by December 31, 2021.
Wallace Loft Actions to Prevent Future Occurrences — Membranes.
The bioreactor membranes utilized at the WWTP have an estimated useful life of at least
ten (10) years, and have been in operation for approximately 8 years. Given the unexpectedly
high load on the membranes since the onset of the Coronavirus pandemic in March 2020 and the
increased maintenance demands on the units, Wallace Loft is in the process of evaluating
available corrective actions, including early replacement of the membranes. Wallace Loft is
obtaining and evaluating bids for corrective actions, and anticipates finalizing a course of action
by the end of this month.
PPAB 6484251v1.docx

August 9, 2021
Page 3
III. The Bypass Was Inadvertent and No Further Bypasses Have Occurred Since the April
2021 Event.
As indicated in the Response, Wallace Loft has been cleaning the membranes on an
approximately weekly basis since the on -set of the Coronavirus pandemic. Typically, the trans -
membrane pressures decrease to well within normal operating range following cleaning
operations. However, following cleaning on Monday, April 19, 2021, trans -membrane pressures
did not drop, and had increased to 2.0 psi by the following day. Wallace Loft promptly initiated an
additional cleaning operation to reduce the trans -membrane pressure, but Wallace Loft was not
able to secure pump trucks to collect and haul excess effluent to the POTW during these
emergency maintenance operations.
Wallace Loft has not been able to determine whether the increased trans -membrane
pressure following the Monday, April 19 event was the result of problems with the cleaning
operations, an unknown slug of unusual wastewater subsequent to cleaning, or another root
cause or cause. However, Wallace Loft has continued the more frequent (weekly) membrane
cleaning schedule, and the issue has not re-emerged, and there have been no further bypasses
associated with maintenance activities or otherwise at the WWTP since the April 2021 event.
Wallace Loft appreciates your consideration of the justification for the remission request
provided in this letter and its attachments. If you have any questions regarding this letter, please
do not hesitate to contact me at fern paterson(a)parkerpoe.com or [phone].
Sincerely,
Fern A. Paterson
Attachments:
Attachment A: Justification for Remission Request Form & Waiver of Right to and
Administrative Hearing and Stipulation of Facts
Attachment B: Wallace Lofts' Response to NOV, dated May 20, 2021
Attachment C: Navitas Equity Solutions — Utilities Optimization & Capital Construction
Plan, June 2021
cc (electronic only):
Lon Snider, NCDEQ (Ion.snider(a)_ncdenr.gov)
Patrick Mitchell, NCDEQ (Patrick.mitchell(abncdenr.gov)
Sean Dwyer(sean.devine(a)cardinalgroup.com)
Justin Pellegrino (iustin.pellegrino _cardinalgroup.com)
Chris Garnic (christopher.garnic _mapletree.com.sg)
Christopher Galante (cgalante(a)mapletree.us)
Rose Hernandez (rose.hernandez(aDthecottagesofboone.com)
David Odom(davidodom(a�-odomengineering.com)
PPAB 6484251v1.docx

JUSTIFICATION FOR REMISSION REQUEST
Case Number: PC-2021-0028 County: Watauga
Assessed Party: Wallace Loft LLC
Permit No.: WO0035784 Amount assessed: $38,541.77
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of to an Administrative Hearing, and Stipulation o�
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in determining
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. By law [NCGS 133-215.6A(f)] remission of
a civil penalty may be granted when one or more of the following five factors applies. Please
check each factor that you believe applies to your case and provide a detailed explanation,
including copies of supporting documents, as to why the factor applies (attach additional pages
as needed).
(a) one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) were
wrongfully applied to the detriment of the petitioner (the assessment factors are
included in the attached penalty matrix and/or listed in the civil penalty
assessment document);
X (b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent
future occurrences);
X (c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you
from performing the activities necessary to achieve compliance).
EXPLANATION:
See attached transmittal letter for detail explanation.
PPAB 6484342v1

STATE OF NORTH CAROLINA NORTH CAROLINA DEPARTMENT
OF ENVIRONMENTAL QUALITY
COUNTY OF WATAUGA
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
WALLACE LOFT LLC 1
PERMIT NO. WQ0035784 ) FILE NO. PC-2021-0028
Having been assessed civil penalties totaling $68,541.77 for violation(s) as set forth in
the assessment document of the Division of Water Resources dated, July 2, 2021 , the
undersigned, desiring to seek remission of the civil penalty, does hereby waive the right to an
administrative hearing in the above -stated matter and does stipulate that the facts are as alleged
in the assessment document. The undersigned further understands that all evidence presented in
support of remission of this civil penalty must be submitted to the Director of the Division of
Water Resources within thirty (30) days of receipt of the notice of assessment. No new evidence
in support of a remission request will be allowed after thirty (30) days from the receipt of the
notice of assessment.
This the 5th day of agust , 2021.
Digitally signed by
Sean A. Dwyer
J' Date:2021.08.06
10:25:56-05'00'
Signature
ADDRESS
Sean A. Dwver
Vice President, Student Living, USA
Mapletree US Management LLC
5 Bryant Park, Suite 2700
New York, NY 10018, USA
TELEPHONE
[phone]
PPAB 6484342v1

Parker Poe
Fern A. Paterson
Partner
t: 704.335.9891
f: 704.335.4456
[e-mail]
May 20, 2021
Via E-mail [lon.snider(cD_ncdenr.gov]
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
NCDEQ — WSRO
450 W. Hanes Mill Rd., Suite 300
Winston-Salem, North Carolina 27105
Atlanta, GA
Charleston, SC
Charlotte, NC
Columbia, SC
Greenville, SC
Raleigh, NC
Spartanburg, SC
Washington, DC
Re: Response to Notice of Violation & Intent to Enforce (NOV-2021-PC-0272)
Wallace Loft, LLC; The Cottages of Boone - Wastewater Irrigation System
Permit No. WQ0035784; Watauga County
Dear Lon:
This response to the above -referenced Notice of Violation ("NOV") is being submitted on
behalf of our client, Wallace Loft, LLC ("Wallace Loft"), which owns and operates The Cottages
of Boone ("The Cottages"). The Cottages holds a NCDEQ Permit No. WQ0035784 to operate a
non -discharge wastewater treatment and irrigation facility (the "WWTP"). As previously reported
to NCDEQ, the equalization tank (the "EQ Tank") at the WWTP began overflowing late
Wednesday, April 21. The overflow event ended at approximately 8:00 a.m. on Friday, April 23.
In this letter, we provide additional information regarding preventative maintenance and other
activities at the WWTP leading up to the overflow event, actions taken immediately prior and
during the event to minimize and stop the discharge, and additional activities already taken and
planned to prevent such discharges in the future. We respectfully request NCDEQ's
consideration of the activities described herein.
Preventative Maintenance and Other Activities at the WWTP Prior to the Discharge
The WWTP includes a Dynatec Membrane Biological Reactor treatment system
comprised of two parallel membrane trains: Membrane A and Membrane B. The Cottages
provides student housing for Appalachian State University. During the Coronavirus pandemic
and associated stay-at-home and work -at-home orders, The Cottages have experienced an
approximate doubling of water usage and wastewater inflow rates.' Prior to the onset of the
' Governor Roy Cooper's initial Stay -at -Home Order took effect on March 30, 2020. Before the stay-at-
home order took effect, the average daily water usage at The Cottages was approximately 35,000
PPAB 6315902v2.docx
Parker Poe Adams & Bernstein LLP 620 South Tryon Street Suite 800 Charlotte, NC 28202
t 704.372.9000 f 704.334.4706 www.parkerpoe.com

May 20, 2021
Page 2
Coronavirus and increased water usage at The Cottages, the membranes were cleaned about
every two weeks. With the approximate doubling of water usage during the pandemic, The
Cottages also doubled the frequency of membrane cleaning operations. The Cottages have been
cleaning the reactor membranes at the WWTP approximately every week since the beginning of
the 2020-2021 school year in Fall 2020.
Further, during lower flow periods prior to the onset of the pandemic, The Cottages could
clean one membrane train while utilizing the other membrane train to keep up with wastewater
influent until cleaning operations were complete; a process that generally takes approximately 12
hours per membrane train. Despite scheduling periodic cleaning operations during the lowest
anticipated flow periods (typically beginning at around 3:00 a.m.), one membrane train has not
consistently been able to keep up with wastewater inflow during cleaning operations since the
pandemic began. As a result, The Cottages engage pump trucks to collect untreated wastewater
from the EQ Tank as necessary during periodic membrane cleaning operations and transport it
to the Town of Boone's publicly -owned treatment works ("POTW").
Actions Taken to Minimize and Remedy the Event
On Monday, April 19, 2021, The Cottages conducted planned cleaning of the WWTP
membranes which, as indicated above, has been occurring on an approximately weekly basis
since Fall 2020. As usual, The Cottages engaged pump trucks to remain on -site throughout the
maintenance operations and to collect and haul influent to Boone WWTP as needed to avoid
overflow of the EQ Tank. After the cleaning operations were completed, both membrane trains
were brought back on-line, consistent with normal procedures. However, by Tuesday, April 20,
2021, trans -membrane pressures increased to greater than 2.0 psi, indicating that the membranes
were clogging and needed to be re -cleaned.
This was highly unusual, as the membrane cleaning events typically keep the membranes
in good working order for at least a week, even during the higher -flow pandemic months. To date,
The Cottages has not determined why the membrane began clogging the day following the April
19 cleaning event. It could have resulted from problems with the April 19 cleaning operation, an
unknown slug of unusual wastewater subsequent to cleaning, or another root cause or causes.
Since the April 19 cleaning, subsequent cleaning operations have reduced trans -membrane
pressures to below the target pressure of 2.0 psi as expected, and the membranes have worked
properly for a week or more between planned cleaning events.
The Operator promptly reached out to multiple pump truck haulers on Tuesday, April 20
requesting trucks at the WWTP so that additional cleaning and maintenance could be conducted.
However, no haulers were available until Friday, April 23, 2021 at the earliest. By Wednesday
evening, clogging in the membranes worsened and the WWTP could no longer keep up with the
influent flowrate at the EQ Tank.
The Operator attempted to engage pump trucks again on Thursday morning but, again,
found that no pump trucks could get to the site until Friday morning. The Cottages had to initiate
cleaning the membranes on Thursday morning, despite the unavailability of pump trucks. Prior
to initiating the cleaning operations, RPB Systems, Inc. contacted Patrick Mitchell of NCDEQ to
provide notification of the discharge on behalf of The Cottages, and notification that cleaning
gallons/day (GPD). By comparison, in Spring 2021, average water usage at The Cottages approximately
doubled and now averages 75,000 GPD or more.
PPAB 6315902v2.docx

May 20, 2021
Page 3
operations would be initiated immediately, during which time only a single membrane train would
be available and operating.
By Thursday evening, Membrane A was cleaned and operational, but The Cottages was
not able to bring Membrane B back on-line due to ongoing maintenance issues. The primary
issue was the malfunction of a 12-inch motor actuated valve located 16 feet off the ground, which
became stuck in the closed position. Additional maintenance personnel were brought in from
Asheville on Friday morning to assist in repairing the motor actuated valve. The discharge ended
on Friday morning at approximately 8:00 am when pump trucks arrived at the site. Maintenance
on the WWTP continued throughout most of Friday, April 23, and both Membrane A and
Membrane B were brought back on-line.
Actions Taken, and Additional Future Actions Proposed, to Prevent a Future Release
Multiple regularly -scheduled weekly membrane cleaning operations have taken place
since the reported discharge without further incident. In addition to returning to regularly
scheduled weekly membrane cleaning operations (and scheduling pump and haul trucks to be
on -site during planned maintenance), The Cottages replaced an existing compressor air dryer at
the WWTP and has replaced (or is replacing) spare parts that were used during the repairs to
keep a redundant set of spare parts on -site. Replacement parts ordered since the event include:
(1) an air dryer unit ($1,600); (2) the 12-inch motor actuated valve; and (3) ten (10) solenoids.
Further, The Cottages has engaged a consultant to evaluate options for reducing water
usage at the facility including, without limitation, the use of water -saving toilets, faucets and other
fixtures. The consultant's initial, desktop review of the existing water systems suggests that water
reductions of 40% or greater may be available. The consultant is scheduled to conduct an on -site
evaluation and review at The Cottages next week to more fully evaluate available options.
Following the repairs discussed herein, on -going membrane cleaning operations at The
Cottages have continued without incident since the April 2021 event. The Cottages further believe
that the easing of the Coronavirus pandemic and associated stay-at-home orders, and water
usage reduction measures identified by the consultant, will reduce the operating demand on the
WWTP. We look forward to working with NCDEQ to resolve the NOV and ensuring full
compliance at the WWTP moving forward. If you have any questions regarding this letter or if
you need additional information, please do not hesitate to contact me at
fern paterson(aD_parkerpoe.com or [phone].
Sincerely,
Fern A. Paterson
cc: Patrick Mitchell, NCDEQ (Patrick.mitchell(a)ncdenr.gov)
Sean Devine(sean.devine(a�cardinalgroup.com)
Justin Pellegrino (iustin.pellegrino(cD_cardinalgroup.com)
Rose Hernandez (rose.hernandez(D-thecottagesofboone.com)
Christopher Galante (cgalante(a1mapletree.us)
Bob Barr (rbarr(a)rpbsystems.com)
PPAB 6315902v2.docx

a\�C ity SoY,
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Empowering Energy Efficiency
EFFICIENCY &EMISSIONS REPORT
Utilities Optimization & Capital Construction Plan
Prepared for Mapletree Investments I Cottages at Boone (Toilet Replacement)
June 2021

aSEquity SONG
Empowering Energy Efficiency
Your facility is likely to consume more than 9.1 million gallons of water during the next 12 months, or a 46% overage. This report provides
recommended efficiency upgrades that if installed will help decrease this overage while creating a quantifiable environmental impact. If
implemented, the Program herein will:
• Meaningfully reduce the blended annual utilities expense at your asset and ensure ongoing expense savings
• Increase the capped value of your facility upon refinance or disposition
• Generate an attractive unlevered ROI on invested capital
EMISSIONS TOTAL
T-12 Consumption (Gallons) 19,809,450
Protected F-12 Consumption (Gallons) 10,681,573
Projected Usage Savings (Yr 1) 9,127,877
%of Historical 46%
CAPITAL REQUIREMENT
Efficiency Program Retrofit Hard/Soft Costs $426,756
Projected Rebates
Net Capital Requirement After Rebates $426,756
2

aSEquity SONG
Empowering Energy Efficiency
Investing for Expense Savings
Below are the recommended efficiency upgrades we've identified alongside projected expense reductions for each:
EMISSIONSEFFICIENCY & AD
The Cottages Boone
ECM Gross Cost
UTILITY CONSUMPTION
SAVINGS (GALLONS) Rebates
Net Cost
ELECTRICAL
WATER/SEWER
High Efficiency Toilets - 0.8 GPF
$295,020
3,466,654 $0
$295,020
High Efficiency Bathroom Sink Aerator - 0.5 GPM
$14,751
2,113,008 $0
$14,751
High Efficiency Showerhead - 1.25 GPM
$24,585
1,683,803 $0
$24,585
High Efficiency Kitchen Sink Aerators - 1.0 GPM
$5,775
864,412 $0
$5,775
In -Unit Water Meters
1 $86,625
1 1,000,000 $0
1 $86,625
!TOTAL: WATER/SEWER
EF6,756
$0
$426,756
TOTAL PROJECT COSTS
$426,756
9,127,877 $0
$426,756

Investing for Environmental Impact I Water
Implementation of an Efficiency Program will help to decrease your ongoing Water consumption in the following ways:
WATER/SEWER USAGE
2,500,000
$2,500,000
2,000,000
$2,000,000
c
0
1,500,000
$1,500,000
1,000,000
$1,000,000
0
500,000
$500,000
Of����������� 11 $0
f i f f f i f f i f f i�
0 0 0 0 0 0 0 0 0 0 -I _4
N N N N N N N N N N N N
a a 5 o z o
�T-12 TOTAL GALLONS F-12 TOTAL GALLONS
T-12 TOTAL $ F-12 TOTAL $
aSEquity SONG
Empowering Energy Efficiency
WATER SAVINGS OF: 9,127,877 Gallons
63.4 13.8
Average Olympic
residential homes OR swimming
for one year 100111�' pools
156.7
Average
residential
lawns
(irrigation)
536,934
O
OR O O O O Average
OO O O personal
OO O 0 showers
Expense
Consumption (Gallons)
Annual Water Savings
Previous 12 Months
$19,809,450
19,809,450
30 Olympic Pools
Next 12 Months
$10,681,573
10,681,573
16.2 Olympic Pools
Decrease of T-12
46%
46%
TOTAL EFFICIENCY
S9.127.877
9.127.877
Savings of 13.8 Olvmoic Pools
An

aC 'quity 8 Y,
Empowering Energy Efficiency
Our Service Lines
SERVICE
DESCRIPTION
Utilities &
We provide initial utilities audits and expert analysis surrounding the feasibility and benefit of upgrading the utilities infrastructure of
Efficiency
commercial real estate facilities you own or manage today. As your Utilities Partner, we also provide the same initial analysis for new
Consulting
acquisitions you may be considering.
Site Audit /
Utilizing degreed and licensed energy managers, professional engineers, and energy consultants, we identify and audit the design,
Efficiency Plan
operation, and maintenance parameters of your Facility to identify efficiency opportunities as well as to create a baseline to benchmark
Design
current utilities consumption. The result of this effort is our Efficiency & Emissions Report alongside a fixed -price utilities upgrade and
project management agreement.
Materials
Sourcing our deep network of trusted suppliers, we procure all of the materials required to achieve the efficiency upgrades outlined in this
Procurement /
report and then act as your project manager overseeing their installation onsite. To do so, we use our vetted list of national, regional, and
Project
local vendors and utilize our experience as former institutional real estate owners/operators to ensure minimal disruption to ongoing
Management
operations and tenant satisfaction.
Rebate &
Upon Project completion, we provide you with all applicable manufacturer warranties on the purchased materials and serve as your Rebate
Warranty
processor, identifying as many available rebates as we can and then tracking their application and award.
Processing
Measurement
Finally, we provide ongoing measurement and verification "M&V" to track the reduced utilities consumption as well as the ongoing utilities
& Verification
Cost Avoidance at the asset level to accurately illustrate progress and to provide full accountability of both the environmental and financial
Services
impact of the efficiency investment. These M&V services provide you with data and sustainability metrics to share with your team and
other outside parties.

aSEquity SONG
Empowering Energy Efficiency
Execution Timeline
The table below illustrates the projected execution timeline beginning upon mutual execution of the contract to Efficiency Program closeout.
PROJECT PHASE
WEEK 1 WEEK 2 WEEK 3 WEEK 4 WEEK 5 WEEK 6 WEEK 7 WEEK 8 WEEK 9 WEEK 10
CONTRACT EXECUTION
Project Awarded / Mutual Contract Execution
PRECONSTRUCTION
Materials Deposit Due (50%of Project Cost)
Kickoff Call
Materials Procurement
Installation Scheduling
EXECUTION
Mobilization & Start -Up
Project Installation
Substanital Project Completion I Quality Control
2nd Deposit Due (40% of Project Cost)
Final Project Completion I Punch
PROJECT CLOSEOUT
Rebate Processing
Warranty Processing
Final Invoicing (10% of Project Cost)
* Timeline above may change to due materials ordering and size of project

Process & Next Steps
1: Site Tour & FINAL Utilities Audit
We've toured your facility and conducted a utilities audit, the findings
included herein. The Efficiency & Emissions Report includes:
• Detailed utilities audit of your facility and step-by-step blueprint
to expense savings
• A fixed -price contract for our auditing & engineering consulting,
materials and labor, we construction management services, rebate
and warranty processing, and Measurement & Verification of
savings upon completion
2: Financing & Installation of Improvements
You fund the infrastructure improvements and we procure the
materials, manages the vendors, and serves as project manager over
the install. If you choose to move forward, we will execute a project
management agreement outlining the terms and conditions of our
utilities consulting, materials procurement, and construction
management services. Project Management Agreement payment
schedule:
PROJECT
$213,378 50% upon contract execution
$170,702 40% upon substantial project completion
$42,676 10% upon full project completion
3: The Contract between Navitas / Owner
Upon project completion, we processes identified rebates and provides
monthly measurement & verification services illustrating the utilities
consumption and cost savings for 12 months.
7
aSEquity SONG
Empowering Energy Efficiency

aC 'quity 8 Y,
Empowering Energy Efficiency
Efficiency Program Technologies
Below is a list of the Efficiency Program upgrades we recommend for your asset.
Water I Water fixtures, in the context of this report, include low -flow fixtures, water line apparatus, and smart irrigation systems.
Technologies I Shower Heads and Aerators
• Niagara High Efficiency Shower Heads are durable, have classic aesthetics, and offer a TamperProof option
• The Bathroom and kitchen aerators
• The 0.5 needle spray bathroom aerator has great pressure to efficiently wash hands
• The 1.5 Dual Spray kitchen has the force to clean dishes
Toilets
• STEALTH fixtures by Niagara can use as little as 0.625 gallons/flush - >50% improvement on the current toilets.
• Vacuum assisted technology that has a MaP premium rating of 800 which is a comparable force to a 1.6 GPF toilet; or a toilet that
uses 2x more water.
• Low flow toilets, the ones that are referred to often, are usually flapper toilets or pressure assisted which creates the following:
1) Pressure Assisted loud and dangerous. Not ideal for residential application because of their supersonic jet -like noise
2) Flapper Toilets are costly, leaky and running. Flapper Toilet Slow gravity fed that lacks force
3) Niagara has a Lifetime Warranty on Ceramic, 10-year on internals with little to no maintenance costs

aC quity8Y,
Empowering Energy Efficiency
Identified Rebate & Manufacturer Warranty Detail
IDENTIFIED REBATES
n/a
MANUFACTURER WARRANTIES
$ AMOUNT
DESCRIPTION & PROJECTED TIMELINE
DESCRIPTION & PROJECTED TIMELINE
High Efficiency Bathroom Sink Aerator - 0.5 GPM 1-year Product Warranty
High Efficiency Showerhead - 1.25 GPM 10-year Product Warranty
High Efficiency Kitchen Sink Aerators - 1 GPM 1-year Product Warranty
Zennergy Flow Management Device 15-year Product Warranty