ATTACHMENT C

U.S. INTERNATIONAL TRADE COMMISSION

In The Matter Of: Investigation Nos.

701-TA-650-651
Phosphate Fertilizers
from Morocco and Russia (Final Investigation)

DECLARATION OF MICHAEL R. RAHM

PURSUANT TO 28 U.S.C. § 1746

1. Introduction

1.1. The purpose of this declaration is to respond to specific issues raised at the February 9

hearing and to expand on a few key points of my argument that imports from Morocco and

Russia did not cause material injury to the U.S. phosphate industry.

1.2. I noted in my responses to questions that the fertilizer year (July 1 to June 30) is the most

commonly used period to analyze market developments in the United States. For example,

the land that farmers plant in the spring is fertilized with phosphate either after the previous

fall harvest or before spring planting. These two application seasons are impacted by

common demand drivers such as input costs and crop prices. The statistics referenced in

my statement or during the hearing were for the U.S. fertilizer year. Import statistics are

from the U.S. Department of Commerce for the three main phosphate solid fertilizer products

– DAP, MAP, and TSP – and prices are from the CRU Fertilizer Week publication. I also

have utilized Stats Canada trade statistics and a Plant City facility profile from CRU. Units

are short tons.

1.3. Given the lack of reliable public or licensed data to measure on farm demand, the analyses

of supply gaps in the U.S. market in Parts 2 and 3 of this Declaration do not take into

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 account any changes in demand, either projected or actual, but demand is another factor

that helps define the supply gap that needs to be filled.

2. Pre-POI Step-Ups in U.S. Phosphate Imports

2.1. Commissioner Johanson asked why the Petition was filed in 2020, if the upward trend of

subject imports dates back more than a decade, as the Petitioner argues. 1 That is a great

question. As I mentioned at the hearing, there are two important step-ups that established a

base level of U.S. imports prior to the period of investigation. In each case, the step-up

followed a plant closure, the threat of a supply loss, or a consolidation, so that imports were

pulled into the United States to fill a current or anticipated supply gap.

Figure 1. Total U.S. DAP, MAP, TSP Imports (Fertilizer Year 2010-2020)

1000 Tons 10 11 12 13 14 15 16 17 18 19 20
DAP 61.4 475.3 69.1 111.7 180.1 823.6 667.9 727.1 1052.4 1385.0 1040.0
MAP 95.6 715.5 428.0 758.1 500.3 1062.3 932.1 1083.8 1443.8 2069.3 1720.9
TSP 141.7 253.3 173.3 314.1 271.1 397.8 242.6 342.6 354.1 362.0 316.2
Total 298.7 1444.1 670.4 1183.8 951.5 2283.7 1842.7 2153.6 2850.3 3816.3 3077.1
Source: U.S. DOC

2.2. Fearing a Spring 2011 Shortage

2.2.1. The first step-up occurred during the 2010/11 fertilizer year. U.S. imports of the

leading solid phosphate products (DAP, MAP, and TSP) averaged 240,000 tons per

year during the five fertilizer years prior to 2010/11. Two events resulted in imports

increasing from 299,000 tons in 2009/10 to 1.4 million tons in 2010/11.

2.2.2. The first event was the idling of Mosaic’s large South Fort Meade mine following a

preliminary injunction issued by a Florida district court in July 2010 that prohibited the

company from mining recently permitted reserves in Hardee County, Florida. The idling

of the mine ignited expectations that Mosaic would run short of product if the dispute

dragged on in the courts. And it dragged on. Mosaic 10-K reports show that South Fort

1 Tr. at 64 (Comm'r Johanson).

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 Meade production dropped 2.7 million tons—from 4.7 million during the 2009/10 fiscal

year ending May 31 to just 2.0 million in 2010/11. The loss of 2.7 million tons of rock is

equivalent of about 1.6 million tons of DAP.

2.2.3. The second event was the closure of the Agrifos facility in Pasadena, Texas, in April

2011. Through a consent decree with the Environmental Protection Agency (EPA),

Agrifos agreed to cease operations when its phosphogypsum stack reached capacity in

early 2011. The plant produced about 625,000 tons of DAP/MAP per year, according to

EPA documents. While the plant ceased operations in April 2011, U.S. distributors

moved quickly to line up alternative supplies for the 2011 spring season.

2.2.4. Fearing a potentially large shortage for the spring 2011 season, the NOLA-Brazil

spread increased to a significant NOLA premium, and imports increased in 2010-Q4

and 2011-Q1. The corresponding increase in imports, particularly from Russia, swiftly

filled the expected domestic market deficit.

2.2.5. As I testified, neither triggering event had anything to with a surge of imports or deep

NOLA price discounting; instead they reflected a preliminary injunction and a consent

decree. The 1.1 million ton increase in imports matched the expected lost output from

the Agrifos Pasadena facility for the spring season (~300,000 tons or one-half of typical

annual production) as well as the expected lost output from the idling of Mosaic’s South

Fort Meade mine (~800,000 tons or one-half of the 1.6 million ton loss that most likely

would have been sold in the domestic market).

2.2.6. U.S. imports declined somewhat following the 2010/11 step-up, averaging 935,000

tons per year from 2011/12 to 2013/14. That was about 700,000 tons greater than the

five-year average of 240,000 tons prior to 2010/11, and generally in line with the lost

output from the closure of the Agrifos Pasadena facility.

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2.3. Diversifying Sourcing Options 2014/2015

2.3.1. The second step-up prior to the POI was in 2014/15. U.S. imports increased 1.4

million tons from the prior three-year average of 935,000 tons to 2.3 million tons in

2014/15. The step-up again resulted from two events – (1) the bankruptcy of

Mississippi Phosphates and closure of its old, inefficient, and unsafe Pascagoula,

Mississippi plant, and (2) Mosaic’s acquisition of the phosphate business of CF

Industries.

2.3.2. The first event, Mississippi Phosphates’s bankruptcy in 2014, had nothing to do with

imports. It demonstrably had everything to do with the facility’s high operating cost and a

range of environmental, health, and safety issues that plagued the operation. For

example, prices published during the week it declared bankruptcy were extraordinarily

promising. DAP and MAP were trading at $415-$420 and $440-$450 per ton fob NOLA,

respectively, and NOLA prices were at a hefty premium to international values.

Meanwhile, the rest of the domestic industry was doing well: Mosaic’s phosphate

business unit had sales of $6.2 billion and generated a gross margin of $1.1 billion in

2014. Even in this environment, the Mississippi Phosphate facility’s performance

struggled. Mississippi Phosphates had capacity to produce about 900,000 tons of

DAP/MAP per year, but produced 685,000 tons in 2012 and 620,000 tons in 2013, with

46% of this tonnage sold to domestic customers. The bankruptcy court’s liquidation

trust ran an auction to dispose of the assets in July 2015, but the auction failed to

secure any acceptable bids.

2.3.3. The second event was Mosaic’s acquisition of the phosphate business of the only

other phosphate producer in Central Florida, CF Industries, at that time the third largest

U.S. producer. The deal was announced on October 28, 2013 and closed in less than

five months on March 17, 2014. This deal coupled with the closure of the Pascagoula

facility reduced the number of U.S. phosphate producers to just four, and left

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 distributors—especially in the Corn Belt—with limited domestic sourcing options. For

example, based on 2019 statistics or estimates for solid phosphate production, the

Herfindahl-Hirschman Index (HHI) for the U.S. industry is currently around 5,880. It is

dominated by Mosaic (~75%) and followed by Nutrien (~11%), Simplot (~11%), and

Itafos (~3%). An industry is considered highly concentrated if the HHI is greater than

2,500.

2.3.4. Of the 1.4 million ton increase in imports in 2014/15, at least one million tons likely

reflected distributors seeking to diversify supply options in response to this latest round

of consolidation. As noted during the hearing, customers indicated to me that while they

loved Mosaic, they simply had to have options. And it was not only Gavilon, Koch, and

ADM that contracted additional tonnage with Moroccan and Russian producers but also

large strategic customers of Mosaic that imported tonnage directly from these foreign

suppliers. It is unfortunate that these players did not participate in the public hearing.

Whether the result of greater industry concentration or distributors bidding up the NOLA

price to attract tons, the NOLA premium climbed to its highest level of the decade during

the first half of 2014, and that led to the second step-up of imports during the 2014/15

fertilizer year. 2

2.3.5. U.S. imports of the leading solid phosphate products then remained stable at this new

level for the three fertilizer years from 2014/15 to 2016/17.

3. Filling the Big Gap During the Period of Investigation

3.1. At the hearing, the Petitioner claimed that the idling of Plant City was caused by an increase

in subject imports prior to 2017. However, after the step-up to 2.3 million tons in 2014/15,

U.S. imports declined to 1.8 million tons in 2015/16 and then increased to 2.2 million tons in

2016/17. In short, there was no surge between Mosaic’s acquisition of the phosphate

2 See Figures 3 & 4.

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 business of CF Industries and its announced idling of Plant City. Imports were stable at the

three-year average of 2.1 million tons during the three fertilizer years prior to the

announcement, and the NOLA price did not trade at a prolonged, deep discount to

international values. In fact, the NOLA-Brazil MAP spread averaged -$1.02 per ton, close to

parity, for the three fertilizer years prior to the announcement. 3

3.2. The public record speaks for itself. Mosaic has been transparent about the fact that the

decision to idle Plant City was part of the company’s overall strategy to optimize operations

and reduce and redirect capital spending. Mosaic indicated that the Plant City facility was its

most inefficient plant. For example, management noted that this facility had more sulphuric

acid plants than other operations and required more maintenance capital. CRU publishes

cost of production reports that include profiles for nearly all major phosphate facilities around

the world. For Plant City, a 2012 report noted that the facility was built in 1965 and was

expanded in 1974. The profile indicates that two single absorption Dorr-Oliver sulphuric acid

plants (old technology) were built in 1965, and two more modern double absorption

Monsanto Enviro-chem Systems were added in 1974. The facility’s four old sulphuric acid

plants are nothing like the modern, large-scale acid plants in operation at the new facilities of

Mosaic’s joint venture in Saudi Arabia. Management also noted that the Plant City facility

was not capable of making its branded performance products and that ammonia had to be

trucked from Tampa terminals rather than delivered more efficiently via pipeline, as is the

case with its other Florida facilities. These publicly stated reasons, not any long blast of

discounted imports, led to the idling and closure of this facility.

3.3. Just two months after Mosaic announced that it was idling the Plant City facility for a

minimum of one year, the merger of Agrium and PotashCorp closed on January 2, 2018.

The newly formed company, Nutrien, announced in early 2018 that it planned to repurpose

3 See Figures 3 & 4.

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 its Redwater, Alberta MAP facility as part of its plan to capture $500 million of deal

synergies. The company estimated savings of $80 million by supplying MAP to its Western

Canadian customers from U.S. operations rather than from the Redwater plant. Although

the plant did not close until May 2019, the race was on to fill the void caused by the closure

of the last phosphate facility in Canada. U.S. MAP exports to Canada nearly doubled from

820,000 tons in 2016/17 to 1.56 million tons in 2019/20, an increase of 740,000 tons,

according to Stats Canada statistics. The big pull north of U.S. shipments to Canada

opened the door for more U.S. imports to backfill this movement. Since Redwater had also

exported a portion of its production to the United States, any lost U.S. imports from Canada

also contributed to the domestic supply gap that needed to be filled.

3.4. The closures of the Plant City and Redwater facilities created a big domestic supply deficit.

Annual capacity of Plant City was 2.2 million tons of DAP/MAP, and average production

during its last two full years of operation in 2015 and 2016 was 1.65 million tons per year,

part of which was exported. Annual capacity of Redwater was 730,000 tons of MAP, and

average production during its last five full years of operation was 600,000 tons per year.

The loss of 2.9 million tons of annual capacity and typical production of 2.2 million tons per

year created a big gap to fill.

3.5. This analysis excludes an estimate of the amount of MAP imported into the United States

from Morocco and then re-exported to Canada. International Fertilizer Association (IFA)

statistics show that OCP reported to the association no direct export sales of MAP to

Canada in 2017, 2018, and 2019. Yet Stats Canada statistics show material MAP imports

from Morocco during this period. The Canadian imports likely are MAP that was imported

into the United States and then sent by rail or truck into Western Canada from U.S. import

ports or inland terminals. The tonnage is not huge but it is material, increasing from 37,000

tons in 2016/17, to 72,000 tons in 2017/18, to 128,000 tons in 2018/19, and to 134,000 tons

in 2019/20. The analysis below uses net U.S. imports, excluding these conservative

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 estimates of re-exports of Moroccan MAP to Canada, which were likely higher in reality.

With respect to Redwater, it is worth noting that even if some of the increase in U.S. exports

to Canada over the POI were actually re-exports of subject fertilizers, my estimate of the

difference between the supply gap and the increase in subject imports would remain the

same, as both the domestic supply gap and the level of subject imports serving the U.S.

market would need to be reduced by the same tonnage.

3.6. U.S. DAP+MAP+TSP imports increased 662,000 tons from 2.12 million in 2016/17 to 2.78

million in 2017/18. Subject imports accounted for all of the gain, increasing 657,000 from

1.67 million in 2016/17 to 2.33 million in 2017/18. Mosaic management reported in March

2019 that the closure of Plant City created a domestic supply gap of 1.1 million tons (or 1

million metric tons) that imports would need to fill. The company also reported that

Hurricane Irma caused a production loss of 440,000 tons (or 400,000 metric tons) in the fall

of 2017. So, lost domestic sales during the 2017/18 fertilizer year totaled about 770,000

tons – 220,000 tons from Hurricane Irma (assuming one-half was destined for the domestic

market) and 550,000 from the idling of Plant City (one-half of the annual total during the first

half of 2018). In other words, the reduction in U.S. domestic supply exceeded the increase

in subject imports by 113,000 tons. U.S. purchasers were bidding aggressively for tons in

2017/18, especially heading into the spring season. The NOLA-Brazil spread averaged $4

per ton for the fertilizer year, with the NOLA premium rising to $20 in December 2017 and

holding at $15 during January 2018. 4

3.7. U.S. imports increased another 910,000 tons from 2.78 million in 2017/18 to 3.69 million in

2018/19. Subject imports accounted for only 68% of the total, increasing 614,000 tons from

2.33 million in 2017/18 to 2.95 million in 2018/19. U.S. imports from Mexico (144,000),

Saudi Arabia (112,000), and Australia (92,000) posted material increases in 2018/19. The

4 See Figures 3 & 4.

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 614,000 ton increase in subject imports was exactly in line with the lost U.S. domestic supply

from Plant City (the remaining 550,000 tons during the second half of 2018) and the

Redwater closure (70,000 tons during the first half of 2019), which sum to a total of 620,000

tons. Nutrien reported producing 230,000 tons before the Redwater plant ceased operations

in May 2019, so the reduction in supply was only 70,000 tons during the first half of 2019.

Distributors likely anticipated an earlier shutdown of Redwater, and the United States

continued to aggressively bid for tons during the second half of 2018. In fact, the NOLA

price traded at an average premium of $6 per ton during the second half of 2018, with that

premium rising to $13 in September and to $15 in October. 5 As a result, total imports,

inclusive of subject imports, increased to nearly 1.6 million tons during the first quarter of

2019 in anticipation of a big spring application season. The NOLA-Brazil spread then

collapsed and total imports plummeted nearly 1.2 million tons during the second quarter of

2019, in response to the spring planting disaster and large build of channel inventories. 6

3.8. The inventory hangover at the end of the spring 2019 season followed by another poor fall

application season kept NOLA trading at a discount to Brazilian values. 7 Compared to

2018/19, U.S. imports declined 746,000 tons to 2.94 million tons in 2019/20. Subject

imports dropped 511,000 tons from 2.95 million in 2018/19 to 2.43 million in 2019/20. The

drop in total imports coupled with the loss of 530,000 tons of MAP production at Redwater

during the 2019/20 fertilizer year resulted in a 1.28-million-ton deficit that was met largely

through the drawdown of channel inventories. Phosphate prices bottomed in December

2019 and had already risen $35 per ton when the CVD petition was filed on June 26, 2020. 8

3.9. The POI spans the fertilizer years from 2016/17 to 2019/20. During this period and before

the petition was filed on June 26, 2020, subject imports increased 761,000 tons from 1.67

5 See Figures 3 & 4.

6 See Figures 3 & 4.
7 See Figures 3 & 4.
8 See Figures 3 & 4.

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 million in 2016/17 to 2.43 million in 2019/20. At the same time, lost U.S. domestic supply

due to the closures of the Plant City and Redwater facilities as well as hurricane losses

totaled 1.920 million tons. Subject imports during these three full fertilizer years filled less

than 40% of the domestic supply gap.

Figure 2.
U.S. Phosphate Subject Import Changes vs. Lost U.S. Domestic Supply: Filling a Big Gap

U.S. Phosphate Subject Import Changes vs. Lost U.S. Domestic Supply
Filling a Big Gap 20-17
Fertilizer Year Ending June 30 Change
1000 Short Tons DAP+MAP+TSP 2016/17 2017/18 2018/19 2019/20 or Total
Total U.S. Imports 2,154 2,850 3,816 3,077 924
Re-Exports of Moroccan MAP to Canada 37 72 128 134 98
Total U.S. Net Imports 2,117 2,779 3,688 2,943 826
Total U.S. Net Imports Change 662 910 (746) 826
Total U.S. Subject Imports 1,710 2,403 3,073 2,569 858
Re-Exports of Moroccan MAP to Canada 37 72 128 134 98
Net U.S. Subject Imports 1,674 2,331 2,945 2,434 761
Net U.S. Subject Imports Change 657 614 (511) 761
Subject Imports Share of Total Imports Change 99% 68% 69% 92%
Hurricane Irma Lost U.S. Domestic Supply 220 0 0 220
Mosaic Plant City Lost U.S. Domestic Supply 550 550 0 1,100
Nutrien Redwater Lost U.S. Domestic Supply 0 70 530 600
Total Lost U.S. Domestic Supply 770 620 530 1,920
Lost U.S. Domestic Supply - Subject Import Change 113 6 1,041 1,159
NOLA-Brazil Spread Average (4) 4 (10) (14)
NOLA-Brazil Spread Monthly High 12 20 15 (1)
NOLA-Brazil Spread Monthly Low (31) (11) (39) (20)
Source: U.S. Department of Commerce, Stats Canada, Company Reports, CRU and MRRC

3.10. The uncertainty caused by the CVD petition as well as a strong rebound in global

phosphate prices caused another sharp decline in total U.S. imports during the beginning of

the 2020/21 fertilizer year. The most recent U.S. Department of Commerce statistics show

that U.S. imports dropped 34% or 540,000 tons during the second half of 2020. Total U.S.

imports likely will decline more than one-third or 1.0 million tons to less than 2.0 million tons

in 2020/21. That follows the 20% or 746,000 ton drop in 2019/20. Unlike last year, however,

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 U.S. distribution channels are completely destocked following a strong fall 2020 application

season.

4. Where are the Domestic Tons?

4.1. Despite a large NOLA premium, U.S. exports of DAP, MAP, and NPS products were down

only 9% or 245,000 tons during the second half of 2020. DAP and MAP exports were off

about 545,000 tons, but exports of NPS performance products were up 40%, or about

300,000 tons, to almost 1.1 million tons during the second half of 2020. Mosaic accounts for

the lion’s share of the NPS exports, and this big gain indicates that the company likely will

continue to build the market for its branded performance products in key offshore

destinations. Mosaic has made sizable investments in production facilities, R&D, and

marketing programs for its NPS products, and has developed customized products that are

tailored for key crops such as canola in Canada and soybeans in Brazil.

5. What Determines U.S. Phosphate Prices?

5.1. The short answer to the question of what determines U.S. phosphate prices is global supply

and demand fundamentals. The price paid for phosphate fertilizer by a farmer in Illinois or

Mato Gross or Heilongjang is determined by a wide array of fundamental drivers, ranging

from input costs to weather.

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Figure 3. NOLA vs. Brazil Price Indices for MAP

Figure 4. NOLA vs. India Price Indices for DAP

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5.2. This fact was little mentioned by the Petitioner’s panel, but it is crucial to any understanding

of price trends in the United States: the phosphate fertilizer market is global, and U.S. and

international prices are closely tied together. In fact, the consolidation of the U.S. phosphate

industry from seventeen firms in 1990 to just four today was approved by the Department of

Justice and Federal Trade Commission based on their assessment that the phosphate

market is a global market. Fundamental developments worldwide, not simply imports from

Morocco and Russia to the United States, explain the absolute and relative price increases

and decreases during the POI. Phosphate prices increased about $150 per ton during the

first half of the POI, and then decreased about $200 per ton during the second half, all

driven by global supply and demand developments.

5.3. The decrease in domestic prices during the second half of the POI also closely tracked

global price levels. The NOLA price traded at a discount to international prices late in the

POI because of two Black Swan events unrelated to the presence of subject imports. As

noted during the hearing, my assessment is that the relative discount in U.S. prices was due

largely to these two demand shocks. The first was excessive rainfall in 2018 and 2019 that

ultimately resulted in farmers not planting 19.6 million acres in 2019—a modern era record

by a wide margin. The idling of 19.6 million acres of mostly phosphate-hungry corn and

soybeans likely resulted in a loss of up to 900,000 tons of demand during the 2019 spring

season. On top of the effects of the extreme weather, the trade war with China led to

reduced U.S. soybean acreage. Crop prices plummeted when China retaliated by placing

high tariffs on U.S. grain and oilseed exports. Based on acreage not planted or diverted to

other less phosphate intensive crops, my assessment is that demand was as much as 1.0

million tons less than what was expected and positioned for sale in 2018/19. Even in a

counterfactual scenario where there was no supply gap or related increase in subject

imports in 2018/19, the domestic industry would have faced the same dynamics and results:

an unanticipated drop in demand, increased inventories, and temporary NOLA discounts.

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5.4. Given these developments, U.S. imports adjusted quickly in response to the 2019 demand

shocks. As noted above, total U.S. imports of DAP, MAP, and TSP increased to 1.6 million

tons in 2019 Q1. Distributors planned for large spring sales due to the poor fall season and

an expected increase in corn acreage. The USDA Prospective Plantings survey showed

that U.S. farmers intended to boost corn acreage 4% to nearly 93 million acres in 2019.

Mother Nature had a different plan. As a result, total U.S. imports collapsed in 2019 Q2,

dropping nearly 1.2 million tons to just over 400,000 tons.

5.5. U.S. net imports from all sources dropped nearly 750,000 tons in 2019/20 as the market

worked down large channel inventories. However, imports did not vanish and should not

have dropped to zero. While floods draw widespread attention, flooding typically impacts a

relatively small area of cropland mainly around the U.S. river system—especially compared,

for instance, to the more widespread devastation typically caused by a severe drought. As

noted, the weather in 2019 was a Black Swan event when rain over much of the Corn Belt

persisted so long that many farmers were unable to plant record-setting areas. However,

despite record prevent plant acreage, the entire Corn Belt was not underwater during the

2019 growing season, and the United States eventually produced a larger-than-expected

corn crop in that year.

5.6. Distributors expected a strong rebound in shipments during the 2019 fall season for several

reasons. The better-than-expected 2019 crop yield removed more-than-expected nutrients

from farm fields, so there was a strong agronomic need. There were signs of improvements

in crop prices and prospects for big rebounds in U.S. planted acreage in 2020. Indeed, the

March 2020 Prospective Plantings survey showed that U.S. farmers intended to plant a

near-record 97.0 million acres of corn, up 8% from a year earlier, and to seed 83.5 million

acres of soybeans, an increase of 10% from the lower level of 2019. The stars and moons

were aligned for strong demand in 2019/20. The 2019 fall campaign turned out to be a

below-average season, again due to weather. As a consequence, the build-up of channel

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 inventories did not get worked down until the end of the strong spring and fall application

seasons in 2020.

6. Conclusion

6.1. The combination of a sharp drop in imports and only modest declines in exports since the

Petition was filed has the United States screaming for tons today. Since hitting bottom in

December 2019, the NOLA barge price of MAP has increased more than 135% or $320 per

ton to $555 per ton, trading at an average premium of $55 per ton since December.

6.2. Moroccan and Russian product has not come into the market simply because the duty-paid

economics do not work, given the high U.S. duties and higher netbacks achievable on sales

elsewhere. With duties on phosphate imports from China, Morocco, and Russia, the

distributors I work with are struggling to find tons from smaller, non-traditional sources. The

top five exporting countries – China, Morocco, Saudi Arabia, the United States, and Russia –

accounted for 90% of total global exports in 2019, according to International Fertilizer

Association statistics.

6.3. As noted at the hearing, my concern is that the trade war tariffs on Chinese imports coupled

with countervailing duties on imports from Morocco and Russia will build a wall around the

United States that is high enough to limit the supplies of phosphate needed by U.S. farmers

and to short circuit the pricing adjustment mechanism that ensures U.S. prices will continue

to closely track global values.

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I declare under the penalty of perjury that the foregoing is true and correct.

Executed on this 17th day of February, 2021.

/s/ Michael R. Rahm

Michael R. Rahm

Independent Consultant, Michael

R Rahm Consulting LLC

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