Rule 2.4 - Information Submitted in
Compliance with CEQA

The transfers of assets for which authority is sought are categorically exempt from the requirement for the preparation of environmental documents and do not have a significant effect on the environment within the meaning of California Environmental Quality Act (CEQA) Guidelines 15300 et seq. Crimson will continue to operate its existing lines consistent with its current authorized use. The purchased assets will not be expanded, and will either be idled or used in accordance with their current authorized use. In order to allow for the idling of certain lines, modifications to segments of the purchased assets will be required. To the extent any construction is necessary to allow the idling of certain lines, such construction will involve (i) a change to existing facilities that does not expand the use or capacity of existing facilities and that is therefore categorically exempt with the meaning of CEQA Guideline 15301; or (ii) the replacement or reconstruction of existing facilities that will be located on the same site as the facility replaced and with the same purpose and capacity as the structure replaced and that is therefore categorically exempt within the meaning of CEQA Guideline 15302. Because the transactions are categorically exempt from CEQA, no Proponent's Environmental Assessment is required pursuant to Rule 2.4. Therefore, it can be seen with certainty that there is no possibility that the project may have a significant effect on the environment.