6033_OrbitEnergy_20210426

From: Wilson, Donna J
Sent: Monday, April 26, 2021 11:32 AM
To: Zack Morgan; Rice, Sarah M
Cc: Greg Kanellis; Stanley, Sherri; Kevin Kearney; Tate Fagan
Subject: RE: [External] RE: 6033-AD-COMPOST-2015, Compliance History Review
Request for Permit Renewal - Orbit Energy Charlotte LLC
Zack,
Sarah and I are reviewing the renewal application. Sarah is reviewing the compliance history review portion,
and I'm reviewing the rest of the application.
We have several other applications ahead of this one, and hope to complete to the review shortly.
The site owner, Orbit Energy/Entropy, is in compliance with our rules for the permit renewal because they have
submitted an application for renewal, even when the permit has expired, assuming the application is
complete. In accordance with 15A NCAC 13B .0202 (d), "When a permit applicant submits a complete
application for a permit to the Division prior to the expiration date of the existing permit for the facility,
including the payment of an annual fee and permit application fee if required by G.S. 130A-291.1 or 130A-295.8,
the existing permit shall not expire until a decision on the permit application is made by the Division."
If you have any questions please let me know.
Donna
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Donna J_ Wilson
Engineering Project Vanager, Solid Maste Section
Division of Maste Management
North C aroli_uaDepartment ofEn-vironmental Quality,
919.707.8255 (Office)
DOMa_1Vi1san, @ncdear_ gov
Physical Address: 217 West Jones Street, Raleigh NC 27603
Mailing address: 1646 Mail Service Center, Raleigh NC 27699
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From: Zack Morgan[mailto:[e-mail]]
Sent: Monday, April 26, 2021 9:39 AM
To: Rice, Sarah M <sarah. [e-mail]>
Cc: Greg Kanellis <[e-mail]>; Stanley, Sherri <[e-mail]>; Wilson, Donna J
<[e-mail]>; Kevin Kearney <[e-mail]>; Tate Fagan
<tate.fagan@ EntropylM.com>
Subject: RE: [External] RE: 6033-AD-COMPOST-2015, Compliance History Review Request for Permit Renewal -
Orbit Energy Charlotte LLC

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attachment to Report Spam.
Ms. Rice,
Good morning. I hope you are well. I wanted to check with you regarding the renewal of the above -referenced
permit. Is there anything further that you need from me in connection with the renewal? I was unclear if there
would be a formal re -issuance or if the permit is now considered renewed. The original term of the permit
expired on March 19 but we timely submitted our renewal application last November.
Thanks,
Zack
Zack Morgan
General Counsel
Entropy Investment Management, LLC
#470157
8326 Pineville -Matthews Road, Suite 407
Charlotte, NC 28226-0147
zack.morgankEntroRyIM.com
[phone] mobile
From: Zack Morgan
Sent: Thursday, February 11, 20213:30 PM
To: Rice, Sarah M <[e-mail]>
Cc: Greg Kanellis <[e-mail]>; Stanley, Sherri <[e-mail]>; Wilson, Donna J
<[e-mail]>
Subject: RE: [External] RE: 6033-AD-COMPOST-2015, Compliance History Review Request for Permit Renewal -
Orbit Energy Charlotte LLC
Thank you for the inquiries, Ms. Rice. I've responded to each of your questions as bracketed in blue
below. Please let me know of anything further.
Thanks,
Zack
Zack Morgan
General Counsel
Entropy Investment Management, LLC
11510 Community House Road
Suite 200
Charlotte, NC 28277
zack.morgankEntropyIM.com
[phone]

From: Rice, Sarah M <[e-mail]>
Sent: Thursday, February 11, 2021 2:59 PM
To: Zack Morgan <[e-mail]>
Cc: Greg Kanellis <[e-mail]>; Stanley, Sherri <[e-mail]>; Wilson, Donna J
<[e-mail]>
Subject: RE: [External] RE: 6033-AD-COMPOST-2015, Compliance History Review Request for Permit Renewal -
Orbit Energy Charlotte LLC
[EXTERNAL]
Good afternoon Zack,
The Solid Waste Section has been reviewing the information provided via email and hard copy. We appreciate
your assistance. The Section has a few questions We hope you could assist with.
1. What is the relationship between Entrophy Investment Management, LLC and Orbit Energy Charlotte,
LLC? [Entropy Investment Management, LLC is engaged by York Capital Management to manage the
operation of Orbit Energy Charlotte, LLC ("OEC") and its sister facility in Rhode Island, Orbit Energy
Rhode Island, LLC. Entropy Investment Management, LLC does not own any equity interest in OEC;
however, my colleague, Kevin Kearney, and I serve as Chief Executive Officer and Chief Operating
Officer, respectively, of OEC for purposes of entering contracts, regulatory compliance, permitting
compliance and transacting business. We are authorized agents for OEC.]
a. It is noted within the renewal document provided to the Section, the property owner is Orbit
Energy Charlotte, LLC c/o Entrophy Investment Management, LLC. [Orbit Energy Charlotte, LLC
is a single purpose limited liability company set up to own and operate the assets forming the
anaerobic digester known as Orbit Energy Charlotte. OEC does not own any other assets other
than the real estate located at 600 Johnson Road, Charlotte, NC 28206 and the structures and
personal property associated with the digester. Because OEC is a single purpose limited liability
company without employees of its own, Kevin and I (through our roles as CEO and COO) serve as
the primary contacts and signatories for OEC.]
b. It is also noted within the annual brownfield Land Use Restrictions Update, that Entrophy
Investment Management, LLC is the asset manager for the majority investor. [Correct.]
2. The principle/ mailing address:
a. As noted within the Secretary of State, the principle address for Orbit Energy Charlotte, LLC has
to 1151 N. Community House Road, Suite 200, charlotte, NC. Please confirm. [Correct. I do note
that we are nearing the end of the term of our lease at that address at the end of the
month. We will provide you with our new address and P.O. Box in a formal notice shortly. In
the meantime, any correspondence can be sent to that address with no problem. I am also
available via email (here at this email) and by cell at 704.941.0890 for less formal
communications.]
Thank you again for your assistance.
Regards,
Sarah
Sarah Rice
Environmental Program Consultant
Division of Waste Management —Solid Waste Section

North Carolina Department of Environmental Quality
919-707-8287 (phone and fax)
[e-mail]
217 West Jones Street
1646 Mail Service Center
Raleigh, NC 27699
NC DEQ: Solid Waste Section
NC DEQ: Financial Assurance (Effective July 1, 2020: REVISED RULES)
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Zack Morgan <[e-mail]>
Sent: Wednesday, January 13, 2021 8:58 AM
To: Rice, Sarah M <[e-mail]>
Cc: Greg Kanellis <[e-mail]>
Subject: [External] RE: 6033-AD-COMPOST-2015, Compliance History Review Request for Permit Renewal - Orbit
Energy Charlotte LLC
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Good morning, Sarah. Attached please find an electronic copy of the documentation that I overnighted to you
on January 8, 2020 at your office as noted in the email below. Please let me know of anything further that you
need to commence your department's review of the Solid Waste Permit Renewal that we have submitted for
the site.
Thank you,
Zack
Zack Morgan
General Counsel
Entropy Investment Management, LLC
11510 Community House Road
Suite 200
Charlotte, NC 28277
zack.morgankEntropyIM.com
[phone]
From: Rice, Sarah M <[e-mail]>
Sent: Monday, January 04, 2021 10:28 AM
To: Zack Morgan <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; Mussler, Ed <[e-mail]>; Watkins, Jason
<[e-mail]>; Wilson, Donna J <[e-mail]>; Aja, Deborah
<[e-mail]>; Bradford, Teresa <[e-mail]>

Subject: 6033-AD-COMPOST-2015, Compliance History Review Request for Permit Renewal - Orbit Energy
Charlotte LLC
[EXTERNAL]
Good morning Mr. Morgan,
The Section is in receipt of Orbit Energy Charlotte LLC's request for renewal of solid waste permit 6033-AD-
COMPOST-2015. Attached you will find a request for an updated corporate level organization chart and
completion of a 5 year compliance review. These requests are standard during the permitting process. Should
you have any questions or concerns, feel free to reach out to me at 919-707-8287.
Regards,
Sarah
Sarah Rice
Environmental Program Consultant
Division of Waste Management —Solid Waste Section
North Carolina Department of Environmental Quality
919-707-8287 (phone and fax)
[e-mail]
217 West Jones Street
1646 Mail Service Center
Raleigh, NC 27699
NC DEQ: Solid Waste Section
NC DEQ: Financial Assurance (Effective July 1, 2020: REVISED RULES)
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to
third parties.