Banking Process The successful location, certification and management of a mitigation bank is a complex process that takes the teamwork of many different professionals to complete. We believe that the banking process is generally made up of these five main tasks: 1. The regional evaluation and site selection (including the feasibility analyses), the process by which Environmental Management Partners finds appropriate mitigation banking sites. 2. Site Acquisition: Initial sites will be put into contract either through direct purchase agreements, options contracts, leasing of public lands or partnering with landowners using investor capital. 3. Wetland Mitigation Bank Certification Process: The certification process results in the execution of a “Banking Instrument” or Memorandum of Agreement with the regional Wetland Mitigation Banking Review Team (MBRT) for each bank site. 4. Site Modification: The site will require modification to change it from a non-wetland to wetland condition. 5. Credit Marketing and Sales: The sale of credits created by the site modification. Below is a more detailed account of the execution of each of these tasks.

Regional Evaluation and Site Selection Identify the most appropriate sites for acquisition or partnership is based on economic, regulatory, and ecological factors. Using a proprietary feasibility evaluation method, this includes a mitigation credit demand database analysis. Potential deals are sourced primarily through two avenues, the deductive “top down” approach and the inductive specific property approach. 1. The deductive “top-down” approach consists of using our proprietary database to find areas that are in need of mitigation credits and then finding the best properties in those regions by putting them through our extensive feasibility analyses. 2. Specific Property. Through this website, word of mouth, and our partners’ various websites, and brokers and other contacts, Environmental Management Partners is presented with many potential mitigation banking sites annually. We then perform our feasibility analyses for that specific property and if it passes our tests we will move forward with attempting to create a mitigation bank out of it. Do you have a potential site that you would like to talk with us about? Feasibility Analyses for Site Selection The product of the feasibility study is the selection of the best sites, or the “jewels,” in a given region. The jewels are the sites that are the most cost effective that will provide the conditions necessary for regulatory approval as a bank. The success of the business depends on identifying the best sites according to four parameters: 1. Ecologically Feasible Site is one that can be developed to produce the highest environmental values possible, within the region (e.g., valuable fish, wildlife, or water quality habitat and function), and the highest number of credits for sale. 2. Economically Feasible Site can be purchased and created for the least cost. The area around the bank site must have the conditions, and potential development demand, that will generate customers. The United States Army Corps of Engineers, plus State, County, and municipal regulators plus proprietary contacts estimate that there will be enough credit demand in the expected Service Area (the area within which the credits can be traded is called the Service Area.) 3. Socially Feasible Site is accepted and supported by the general public, property neighbors, and other concerned citizens (e.g., Native American tribes, environmental groups). 4. Politically Feasible Site is one that can be created with the approval of the local, state, and federal regulations. Site Acquisition Initial sites will be put into contract either through direct purchase agreements, options contracts, leasing of public lands or partnering with landowners using investor capital.

Mitigation Bank Certification Process The certification process secures the Banking Instrument or Memorandum of Agreement with the regional Mitigation Banking Review Team (MBRT) for each bank site. This is the legal creation of the bank whereby the property and the plan for its conservation or restoration and long-term management has been agreed to by the Agencies that represent the MBRT. The certification process can take between 12 - 36 months to complete. Below is the “task” list of the certification process: Phase I: Preliminary Negotiations Task 1.0 - Preliminary Site and Regional Analysis Task 2.0 - Coordination of, and Preparation for, Preliminary Application Meeting Task 3.0 - Project Team Strategy Meeting Task 4.0 - Preliminary Application Meeting Task 5.0 - Project Team Evaluation and Phase II Proposal Phase II: Wetland Delineation, Habitat Evaluation, and Jurisdictional Determination Task 6.0 - Jurisdictional Baseline Evaluation Task 7.0 - Wetland Boundary Delineation Task 8.0 - Wetland Evaluation Task 9.0 - Mitigation Master Plan Phase III: Mitigation Bank Prospectus Task 10.0 - Mitigation Bank Draft Prospectus Task 11.0 - Mitigation Bank Final Prospectus Sub-Task 11.1 - Wetland Delineation Documentation Sub-Task 11.2 - Prospectus Graphics Sub-Task 11.3 - Prospectus Presentation Task 12.0 - Mitigation Bank Prospectus - Post Presentation Revisions Phase IV: Mitigation Bank Negotiations Task 13.0 - Mitigation Bank Negotiations Task 14.0 - Wetland Functional Analyses Task 15.0 - Wetland Special Studies Task 16.0 - Mitigation Bank Site Development Plans (Draft and Final) Task 17.0 - Mitigation Bank Site Monitoring Plan (Draft and Final) Phase V: Mitigation Banking Instrument Task 18.0 - Draft Mitigation Banking Instrument Sub-Task 18.1 - Conservation Easement (Draft and Final) Task 19.0 - Final Mitigation Banking Instrument

Site Modification The site will require modification to change it from non-wetland to wetland condition. The creation of a wetland takes on much the same form of any real estate development project. Initially the design is created to fit the needs of the client, who in this case is actually the MBRT and the likely credit buyers. Once there is an agreement between the MBRT and the bank operator on the types of wetland, the blue print for how the site will be modified and restored, and the amount of credit that will be created, the actual creation of the bank can begin. Environmental Management Partners can either completely outsource the creation of the physical mitigation bank, or at times will take on a direct management role when appropriate.

Marketing Strategy The marketing strategy for a mitigation bank is far different than for most industries for the simple fact that all possible purchasers of credits have to obtain a permit to cause the impact that they would need the credit for. This enables mitigation bankers to know of all potential customers by reviewing the public records of the permit offices. However this does not ensure that a potential customer will decide to purchase our credits. Because of this our marketing strategy is designed to maximize opportunity to sell wetland credits. We have a proactive sales approach that gives us the best chance of capturing the greatest share of demand possible.