BIOIMPACT, INC. P.O. BOX 132 KINGSHILL ST. CROIX. U.S .VIRGIN ISLANDS 00851 February 18, 2016 Erika A. Kellerhals Member Kellerhals Ferguson Kroblin PLLC 9100 Port of Sale Mall Suite 15 St. Thomas, VI 00802 Re: Great St. James Permitting Dear Erika, Thank you for contacting Bioimpact, Inc. in regard to the permitting for Great St. James. I have listed each item separately and provide a discussion of how I feel we should best approach the permitting. I have also provided a detailed discussion of what will be required and finally have provided a cost for these services. Existing Well and TPDES I would like to contact Syed Syedali and Jeffery Johnson at the Division of Environment Protection and check on the status of the well and if there is a well water allocation permit. They will be pleased that the new owner is reaching out to get the well in to compliance. We need to get an idea on the existing RO capacity and based on the fact it was operating we can assume that the well is capable of producing that much volume. We could also get a draw down test done of the well to determine the potential volume if a larger RO is desired. We should analyze the water quality to determine if its drawing fresh water, brackish water or saltwater. In any event we will have to apply for the allocation permit and it usually only takes 2 to 3 weeks to get the permit issued especially since we should have no issues since there is no one else in our aquifer. Once we know the size of the RO and figure out where we are discharging I can get the TPDES application filled out and in. This unfortunately can take a while; by regulation they have 180 days to evaluate the permit. We should be able to this much quicker if we push on Vernill Roberts who is in charge of TPDES permits. Also if we are thinking of putting in a small Waste Water Treatment Plant(WWTP) we will need to include the WWTP in the TPDES as well. Utilizing a small plant will provide effluent to irri