DRC_EXHIBITS_AQUACROSSINGS_051226.PDF
City of Tempe — Development Review Commission Regular Meeting (2026-05-12)
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EXHIBITS for AQUACROSSINGS (PL260123) 1. Zoning Map 2. Aerial Map 3-7. Letter of Explanation 8. Site Plan 9. Floor Plan 10-12. Context Photos 13-14. Zoning Administrator’s Opinion – Similar Use Ruling 15-17. AquaCrossings Mechanical and Process Improvements 18-36. Public Input ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! Enterprise GIS and Data Analytics Group; City of Tempe , Vantor General Industrial District (GID) Commercial Shopping and Services (CSS) Single-Family Residential (R1-6) Multi-Family Residential (R-2) ! ! ! ! ! ! ! ! Multi-Family Residential Restricted (R-3R) ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! Multi-Family Residential Limited (R-3) Multi-Family Residential General (R-4) . AQUACROSSINGS PL260123 EXHIBIT 1 SITE GID Enterprise GIS and Data Analytics Group; City of Tempe , Microsoft, Vantor ² Aerial Map AQUACROSSINGS PL260123 EXHIBIT 2 Letter of Explanation Use Permit Application AquaCrossings 1818 W. 4th Street Tempe, Arizona 85281 To the City of Tempe Community Development Department: AquaCrossings respectfully submits this Letter of Explanation in support of its application for a Use Permit for its existing operations at 1818 W. 4th Street in Tempe, Arizona. AquaCrossings provides environmentally conscious end-of-life care for companion animals through a controlled, indoor alkaline hydrolysis process, also referred to as aquamation, along with related aftercare services for pet-owning families and veterinary partners. The City’s Zoning Administrator’s Opinion determined that the use should proceed through the Use Permit process, and this application is submitted in good faith to address the applicable standards under Section 6-308(E) of the Tempe Zoning and Development Code. Description of Use and Operations AquaCrossings operates an enclosed, electrically powered, water-based process that reduces companion animal remains to sterile mineral remains for return to families. The process takes place entirely indoors in sealed equipment. It involves no combustion, no incineration, no furnace, no open flame, and no direct air emissions. AquaCrossings also provides related aftercare services, including coordination with veterinary clinics, respectful intake and release of remains, clay paw prints and other memorial keepsakes, and limited family service connected to pet aftercare. The interpretation packet submitted to the City described the operation as a controlled industrial process with no furnace, no open flame, and no air emissions, and also noted that all processing and keepsake production occur indoors. Operations are low-intensity and controlled. Family visits are limited and do not involve continuous public traffic. Much of the business is conducted through veterinary partners, coordinated pickup and delivery services, and carefully managed appointment-based interactions. AquaCrossings also coordinates licensed veterinary euthanasia services in connection with its broader end-of-life care model, further reflecting the professional and controlled nature of the operation. The interpretation packet explained that such veterinary-related activity occurs by appointment only and involves a single animal at a time. EXHIBIT 3 Hours of operation: 7:00 AM to 5:00 PM, seven days per week Number of employees on site: Approximately 10 employees at any given time Customer traffic: Limited and low in volume Deliveries and pickups: Limited, scheduled, and conducted in a discreet manner Effect on the Surrounding Area AquaCrossings is located within an industrial area and operates in a manner that is compatible with surrounding industrial and commercial uses. The use is fully indoors, low traffic, and low intensity in terms of visual, noise, and operational impacts. The process itself is quiet, does not emit smoke or glare, and does not create the nuisance characteristics typically associated with combustion-based cremation. AquaCrossings’ operations have also been affirmatively supported by surrounding neighboring businesses. As reflected in the neighbor support letters and signatures included in Exhibit C of the interpretation packet, all occupied neighboring businesses that submitted support confirmed that AquaCrossings does not create an exterior odor nuisance, does not disrupt adjacent operations, and remains compatible with surrounding industrial uses. This direct feedback from businesses working immediately around the site is strong evidence that the operation is not detrimental to persons working in the vicinity, adjacent properties, or the surrounding area. No changes to building setbacks or other development standards are requested as part of this Use Permit application. Accordingly, no setback-related impacts to adjacent properties are anticipated. Use Permit Standards / Section 6-308(E) a. Significant vehicular or pedestrian traffic in adjacent areas The proposed use will not generate significant vehicular or pedestrian traffic in adjacent areas. AquaCrossings is not a high-volume retail use and does not attract frequent walk-in customers. Family visits are limited, and most business is conducted through veterinary partners or coordinated pickup and delivery services. The use therefore produces materially less customer traffic than many traditional commercial or service uses. AquaCrossings’ previous submission also emphasized that veterinary-related activity occurs by appointment only and involves a single animal at a time. b. Nuisance arising from odor, dust, gas, noise, vibration, smoke, heat, or glare exceeding ambient conditions EXHIBIT 4 The proposed use will not create nuisance conditions exceeding ambient conditions in the surrounding area. ● Odor: The aquamation process itself does not generate odor. While natural decomposition odor may occasionally be present inside the building upon intake of remains, AquaCrossings has invested in ventilation and filtration systems designed to contain any such interior odor and prevent exterior impacts. The interpretation packet stated that no exterior odors are generated and that interior odors are fully contained through professional ventilation and filtration. This conclusion is also supported by signed statements from surrounding neighboring businesses confirming that no exterior odor or nuisance has been created by AquaCrossings’ operations. ● Dust / Gas / Smoke: The process involves no combustion, no incineration, no furnace, no open flame, and no direct air emissions. As a result, the use does not produce smoke, soot, dust, or combustion gases. The technical materials submitted to the City likewise explained that alkaline hydrolysis does not produce the air-quality impacts associated with flame cremation and does not require a smokestack. ● Noise / Vibration: The operation is indoors and involves enclosed equipment. Noise levels are low and are not expected to be perceptible outside the building at a level exceeding ambient industrial-area conditions. ● Heat / Glare: The use does not create exterior heat or glare impacts. There is no open-flame process and no exterior lighting beyond standard site lighting. For these reasons, the use will not create nuisance conditions to adjacent properties, persons working in the vicinity, or the public welfare in general. c. Contribution to deterioration of the neighborhood or downgrading of property values The requested Use Permit will not contribute to deterioration of the neighborhood or the downgrading of property values. To the contrary, AquaCrossings is a clean, quiet, low-traffic business that operates indoors and has invested in maintaining a respectful and professional facility. The operation does not create the visible or operational conditions commonly associated with heavy industrial or nuisance uses. AquaCrossings has operated in Tempe for several years and has sought to remain a transparent and responsible business within the community. The interpretation packet also noted that the business has operated for more than four years as a respectful and community-minded operation. The use is consistent with the character of a General Industrial area because it is operationally controlled, primarily indoors, and compatible with neighboring industrial and service uses. Approval of this Use Permit would allow a specialized, low-impact business to continue operating under clear regulatory conditions without creating adverse land-use impacts. EXHIBIT 5 d. Compatibility with existing surrounding structures and uses The proposed use is compatible with the surrounding industrial and commercial context. The facility is fully enclosed and does not require exterior industrial infrastructure such as stacks, burners, or large rooftop emissions equipment. The use functions more like a controlled indoor processing, laboratory, or veterinary-support environment than a traditional combustion-based crematory. AquaCrossings’ prior interpretation packet also explained that the process is conducted entirely indoors within sealed equipment and that wastewater compliance was separately reviewed by Tempe Environmental Services, which determined that an Industrial User Discharge Permit was not required at that time. The proposed use therefore fits the surrounding area in terms of traffic, building function, scale, and operating impacts. It is discreet, contained, and compatible with the existing neighborhood pattern. e. Adequate control of disruptive behavior inside and outside the premises AquaCrossings maintains adequate control of activity both inside and outside the premises. The business is not a late-night entertainment use, gathering place, or high-volume public venue. Customer interactions are limited, sensitive, and typically coordinated in advance. Operations are conducted by trained staff in a professional setting. Deliveries, pickups, and handling procedures are coordinated in a controlled and respectful manner. There is no anticipated disruptive behavior associated with the use. In addition, the business has every incentive to operate quietly and professionally given the nature of its services and the importance of maintaining trust with veterinary partners, families, and neighboring businesses. Conclusion AquaCrossings respectfully requests approval of the Use Permit for its operations at 1818 W. 4th Street. The proposed use is a low-impact, fully indoor, professionally managed operation that will not be detrimental to persons residing or working in the vicinity, to adjacent properties, to the neighborhood, or to the public welfare in general. It will not create significant traffic, nuisance impacts, neighborhood deterioration, incompatibility with surrounding uses, or disruptive behavior. The operation is controlled, discreet, and appropriate for approval subject to any reasonable conditions the City may wish to impose. AquaCrossings appreciates the City’s consideration of this request and looks forward to continuing to operate responsibly and cooperatively within the City of Tempe. Respectfully submitted, EXHIBIT 6 AquaCrossings Matthew Mansour and Michelle Vander Lugt Owners 4/6/2026 EXHIBIT 7 EXHIBIT 8 STE 1 FRONT DESK AREA MPR 2 MPR 1 OFFICE 2 OFFICE 1 OPEN WORK AREA ELEC LAUNDRY STE 2 ACC. RR STAFF RR 10' - 1" 10' - 7" HOLD 4' - 0" EQ 8' - 3" EQ 8' - 3" 13' - 0" MOP SINK W D WH WH WH PET 550 VERIFY 30' - 0" PET 550 PET 550 CL OF WALL AND COLUMN LINE ACC. RR BREAK 1' - 6" WTR FEAT/DSPLAY WAITING CREMATION 12' - 3" 11' - 8" KITCHENETTE COFFEE GLASS WALLS 7' - 0" 13' - 7" Bone drying room Laundry Area Aquamation area Paw printing area Packaging area Lobby area Office Office Office Office CSR Area Bathroom Bathroom Bathroom 1818 W 4th St Tempe Az 85016 EXHIBIT 9 Front of the building Side of the building EXHIBIT 10 Back of the building Operations Area EXHIBIT 11 Office area Lobby area EXHIBIT 12 City of Tempe Community Development Department Planning Division Mail Stop 01-7 PO Box 5002 Tempe, AZ 85280-5002 www.tempe.gov March 30, 2026 Wendy Riddell Berry Riddell LLC 650 E. Camelback Rd. #100 Scottsdale, AZ 85251 wr@berryriddell.com RE: AQUACROSSINGS Zoning Administrator’s Opinion - Similar Use Ruling 1818 West 4th Street DS260256 / PL260062 / ADM260009 Dear Ms. Riddell, As designated Zoning Administrator for the Community Development Department, I have conducted an official similar use ruling for the business located at 1818 West 4th Street, in the GID, General Industrial District. Pursuant to the Tempe Zoning and Development Code (ZDC), Section 6-301, “Any use not appearing in this Code which is similar to, and not more detrimental than the uses permitted herein, as determined by the Zoning Administrator, may be permitted based on a code interpretation and similar use ruling.” The following Zoning Administrator’s Opinion has been issued. The applicant at the above address is seeking similar use ruling through a Zoning Administrator’s Opinion based on a land use violation case brought forward by Code Compliance. Because such business is unspecified within the Zoning and Development Code and not classified by the Zoning Administrator, such use is prohibited in any district, unless a Similar Use Ruling interpretation is made. The business, AquaCrossings, located at the address above is described by the applicant’s representative: “Aqua Crossings provides environmentally conscious end-of-life care for companion animals through a controlled industrial process known as alkaline hydrolysis, also referred to as aquamation.” “AquaCrossings’ primary operations consist of a non-combustive, water-based chemical process that utilizes electrically powered, enclosed equipment to chemically alter organic material, reducing it to inert mineral remains and sterile aqueous effluent. The process involves no combustion, no incineration, no furnace, no open flame, and no air emissions. To read more about the aquamation process, please see the letter included as Exhibit A from the manufacturer of the aquamation equipment. In response to this request, the Zoning Administrator has made the following similar use ruling, that the business, AquaCrossings, is described as “aquamation” (or water-based cremation) and such use is similar to and not more detrimental than the uses described in the land use category of “Cemetery, Crematorium, Mausoleum” in the GID, General Industrial District. As such a business with aquamation facilities would require the processing of a Use Permit before operating, pursuant to the requirements in Section 6-308 of the ZDC. The use must also address complaints and issues of odors emanating from the facility that are factors in evaluating the appropriateness of the use. Aquamation (also called alkaline hydrolysis or water cremation) is similar to cremation in purpose - they both reduce a body to remains that can be returned to loved ones - but they differ in process and EXHIBIT 13 environmental impact. Internet research suggests aquamation is commonly referred to as “water cremation” as opposed to the more traditional “fire cremation”. Both processes result in decomposing a body (whether human or an animal) using a process to disintegrate the remains into bone fragments and ashes. While fire cremation can use a direct flame for intense heat, the water cremation of aquamation also uses a high heat around 300 degrees Fahrenheit for the decomposing process. Aquamation is said to be more environmentally friendly. In short, same goal, different process. The subject matter experts from another aquamation business, Bio-Response Solutions, provided multiple arguments on why the fire cremation process is not the same as aquamation, but even noted the similarities and continued comparison of fire cremation and water cremation: “While cremation, burial, and alkaline hydrolysis all achieve the same end result, reduction of organic material leaving inorganic mineral remains these are not comparable processes. Alkaline hydrolysis bears no more similarity to flame cremation than burial does.” A similar use ruling does not define use to become identical or the same as one another. Rather we look for similarities or comparisons in the business function that would result in treating both uses under the same land use process. The Zoning and Development Code, land use chart within Section 3-302 of the Office/Industrial District identifies “Cemetery, Crematorium, Mausoleum” under one land use category. The uses are not the same, but they are categorically similar in nature which the business provides a final disposal or resting place of human or pet remains. A Cemetery is not the same as a crematory, yet the land uses are defined categorically in the Zoning and Development Code as similar business traits in dealing with remains. The most convincing evidence is the information about aquamation and the differences and similarities of fire cremation found within the AquaCrossings’ very own website. Their own business slogan describes themselves as “AquaCrossings, Sustainable water-based cremation”. Their website goes on to explain, What is Pet Aquamation? “Pet aquamation, also known as water-based cremation or alkaline hydrolysis, offers a gentle alternative to traditional fire-based cremation. This innovative method mirrors a natural process, using a blend of water and alkali to return your pet to their natural elements.” The web pages have been updated since the filing of a similar use rulings request. Copies of the original website material were made by Code Compliance that are historical reference materials for this case. Any person or entity aggrieved by this decision may appeal to the Board of Adjustment within fourteen (14) calendar days, from the date of this letter, by filing a notice of appeal with the Community Development Department, specifying the grounds for such appeal and paying the applicable fees. Please see Section 6-803 of the ZDC (Appeal Criteria) for details. After receipt of an appeal application, a public hearing for an appeal will be scheduled at the next regular meeting of the Board of Adjustment. Appeals must be filed with the Community Development Department and an application filing using the Citizen Access Portal: https://epermits.tempe.gov/CitizenAccess/Default.aspx Should you need further assistance or clarification on this matter, please contact staff at (480) 350-4311. Sincerely, Ryan Levesque, designated Zoning Administrator Deputy Community Development Director – Planning Community Development Department EXHIBIT 14 Work Report: AquaCrossings Project To: City of Tempe – Development Services / Project Management From: Contract Modular LLC Date: April 8, 2026 Subject: Summary Mechanical and Process Improvements – Aqua Crossings Project Overview This report summarizes the specialized mechanical installations and environmental mitigation work performed by Matter AC at the Aqua Crossings facility in Tempe, Arizona. The scope of work started in October 2025 and is continuing, focusing on industrial ventilation and odor control. Qualifications Statement Matter AC brings extensive technical expertise in complex mechanical and environmental requirements of large-scale agricultural operations. Most notably, our team spearheaded high-capacity ventilation and odor containment projects for Hickman Family Farms, specifically within their raw food processing and industrial rendering plant facilities. Rendering operations present some of the most rigorous challenges in the industry, requiring precise management of high-heat loads, extreme humidity, and high-intensity organic odors. Our experience at Hickman’s involved the design and installation of robust mechanical systems capable of maintaining negative pressure environments to prevent fugitive emissions. We are intimately familiar with the process requirements for atmospheric stabilization and the integration of industrial-grade scrubbing and filtration systems. By leveraging this background, we ensure that every project meets industry standards for air exchange efficiency and community odor mitigation. AZ ROC# 353686 CR-39 Page | 1 EXHIBIT 15 Detailed Work Log Date Range Work Performed Description Oct 6 – Oct 10 Roof Equipment Venting Remove and install new primary equipment vents to the roof line to address odor. Nov 12 – Nov 19 Odor Mitigation Supplied and installed a temporary blower assist venting system to mitigate environmental odor and address air quality standards. Dec 5 – Dec 30 Odor mitigation Change temp equipment to optimize the venting on 2 of the process machines. Jan 3 – Jan 7 Supplemental Odor Control Follow-up phase for odor issue remediation; Installed final caustic environment exhaust blower. Jan 23 – Jan 26 Machine Ventilation Hi-Temp Exhaust Ducts Fabrication and installation of specialized high-temperature exhaust ductwork for thermal-intensive processes. Feb 3 – Feb 11 Manufacturer Ventilation Design Manufacturer provided a design for venting the 2 large process machines. Feb 13 – Feb 15 Machine Vents Install venting systems per manufacturer drawings. AZ ROC# 353686 CR-39 Page | 2 EXHIBIT 16 Technical Summary ● Environmental Compliance: The odor mitigation phases were undertaken to significantly reduce the facility’s external environmental impact. ● Infrastructure Durability: High-temperature ductwork was installed using materials rated for industrial-grade thermal stress to ensure long-term system integrity. Next Steps: Enhance Ventilation and Odor Containment We are designing a mechanical system to exceed 15 air changes per hour. Given this high rate of air exchange, the primary objective is to establish a negative pressure environment within the facility. By maintaining a lower internal pressure relative to the exterior, we will ensure that all air is drawn inward, effectively preventing untreated odors from escaping through building apertures. This controlled airflow will be strategically routed through high-efficiency filtration units, ensuring that all exhaust air is fully scrubbed and neutralized before being released into the atmosphere. Daniel Hall Managing Member 1711 E Missouri Ave, Suite 11 Phoenix, AZ 85016 602-341-3050 AZ ROC# 353686 CR-39 Page | 3 EXHIBIT 17 EXHIBIT 18 EXHIBIT 19 EXHIBIT 20 EXHIBIT 21 EXHIBIT 22 EXHIBIT 23 EXHIBIT 24 EXHIBIT 25 EXHIBIT 26 EXHIBIT 27 EXHIBIT 28 EXHIBIT 29 EXHIBIT 30 EXHIBIT 31 EXHIBIT 32 EXHIBIT 33 EXHIBIT 34 EXHIBIT 35 EXHIBIT 36