Above is a picture of methyl bromide emissions control equipment installed at Guadalupe Cooling in Nipomo, CA.

Hello, my name is Peter Joyce, President of Value Recovery, Inc.

https://www.valuerecovery.net.

I am requesting funds to force the EPA to add fumigation to the Clean Air Act as a source category under section 112c of the Act. Forcing the EPA to require emissions controls for all fumigation sources more significant than 10 tons/yr of methyl bromide will protect the ozone layer. Methyl bromide is a fumigant used in over 20 ports in the United States to destroy invasive insects hitchhiking on imported goods and is vented directly to the atmosphere after fumigation. Once methyl bromide reaches the upper atmosphere, it degrades the ozone layer that protects us from harmful Ultra Violet (UV) rays from the sun that can cause skin cancer. The EPA does not list fumigation as a source category within the Clean Air Act, even though it is legally required to do so. This loophole allows major sources of methyl bromide emissions to operate without emissions controls. And there are over 20 ports in the United States that vent methyl bromide directly.

The legal justification work is complete, with much more detail on these arguments and can be obtained by seeing the notice of intent to sue on our website at EPA Issue. This notice of intent to sue the EPA was written in 2015. Why is this being executed now? First, it was put on the EPA's website to wake them up to this egregious oversight of their regulations. It didn't. Then Mr. Trump became President, and it was obvious to us that engaging the EPA on this issue would be a waste of time. After Mr. Biden became President, we feel we have a better chance of the EPA responding to this notice and changing its regulations before litigation proceeds. However, we need the funds if the EPA refuses to budge.

The use of the funds is solely to hire a significant environmental legal firm to take on the EPA and for the result of adding fumigation to the Clean Air Act as a Source category. The funds will not be used by the company for any other purpose. Requiring fumigation to be a source category will legally force emissions controls on all sources in the United States greater than 10 tons/yr of methyl bromide. Please know that this change in the law will require emissions controls - but not necessarily by my company, even though our process is listed as BACT in California and has 5 independent source tests that prove its efficacy. A schematic of our process is shown below. Also, please find our scrubber's chemical reaction that destroys methyl bromide.

Thank you for your attention to this matter and please send me a note if you have any questions.

Peter J. Joyce

President

Value Recovery, Inc.

525 Route 73 North, Suite 104

Marlton, NJ 08053

www.valuerecovery.net