1. Regulatory Compliance Environmental Matters Breakout Session April 21, 2016

2. Moderator:  Karen Caldwell, Owner, Caldwell Compliance Panelists:  Michael Way, Senior Regulatory Compliance Manager, Caldwell Compliance  Annelise Morris, Regulatory Compliance Analyst, Caldwell Compliance Panelist:  Emily Painter, Site Acq. Project Manager, Centerline Solutions Confidential and Proprietary 2 Moderator and Panelists

3. Effective Environmental Compliance Management April 21, 2016 Michael Way, Senior Regulatory Compliance Manager Annelise Morris, PhD, Regulatory Compliance Analyst 3 Confidential and Proprietary

4. 4 Effective Environmental Compliance Management  Compliance does not always have to be a gating factor to Construction  Four Keys to Successful Regulatory Compliance Management: 1.Effective Communication 2.Procedural Understanding of Regulations 3.Procedural Understanding of Client Requirements 4.Effective Vendor Management

5. Confidential and Proprietary 5 Effective Communication  Regulatory Compliance is a team sport!  Shared Goal: Clearing Site for Construction

6. Confidential and Proprietary 6 Effective Communication  Facilitate effective communication between Site Acquisition, Environmental Vendor, carrier, and internal/third party quality control reviewers  Keep everyone looped in on challenges and changes  Coordinate to ensure minimal landowner disturbance  Work collaboratively to resolve issues  Manage and keep all parties apprised of expectations

7. Confidential and Proprietary 7 Procedural Understanding: Federal and State Regulations  Regulations are not optional nor flexible  Thorough knowledge of regulatory requirements ensures proper scope of compliance work is completed  Knowledge of exclusions and their applicability ensures the right amount of compliance work is done  Comprehending Timelines

8. Confidential and Proprietary 8 Procedural Understanding: Client  Understand client’s interpretation and implementation of regulations  Familiarity with client databases  Comprehension of client’s Phase I ESA requirements  Comprehension of client’s NEPA requirements

9. Confidential and Proprietary 9 Effective Management  Knowledge of regulatory requirements and timelines are put into practice by driving and managing vendors to adhere to internal (client) and external (federal and state) requirements  Quality Control of Environmental Vendors’ Reports  Evaluation of Environmental Vendor Performance  Proactive Troubleshooting of Procedural Issues  Vendor Consistency

10. Confidential and Proprietary 10 Questions?

11. Thank You Confidential and Proprietary 11 Michael Way Senior Regulatory Compliance Manager michaelway@caldwellcompliance.com (707) 853-0800 – cell (925) 201-1102 x107 - office Annelise Morris Regulatory Compliance Analyst annelisemorris@caldwellcompliance.com (510) 542-9634 – cell Karen Caldwell President/Owner karencaldwell@caldwellcompliance.com (925) 570-9462 – cell (925) 201-1102 x107 - office