NRC-2025-0025, Comment (001) from James Poole on PR-72 - List of Approved Spent Fuel Storage Casks: NAC International, Inc., NAC-UMS Universal Storage System, Certificate of Compliance No. 1015, Renewed Amendment No. 10, and Revision 1 to Renewed Ame

Comment (001) from James Poole on PR-72 - List of Approved Spent Fuel Storage Casks: NAC International, Inc., NAC-UMS Universal Storage System, Certificate of Compliance No. 1015, Renewed Amendment No. 10, and Revision 1 to Renewed Amendmen

ML26012A381
Person / Time
Site:	07201015
Issue date:	01/06/2026
From:	Justin Poole Obelisk Tech Systems
To:	NRC/SECY
References
NRC-2025-0025, RIN 3150-AL30, 90FR56697
Download: ML26012A381 (0)

Text

PUBLIC SUBMISSION As of: 1/9/26, 5:17 PM Received: January 06, 2026 Status: Pending_Post Tracking No. mk2-czah-jdba Comments Due: January 07, 2026 Submission Type: Web Docket: NRC-2025-0025 List of Approved Spent Fuel Storage Casks: NAC International, Inc., NAC-UMS Universal Storage System, Certificate of Compliance No. 1015, Amendment No. 10, and Revision to Amendment Nos. 5 through 9 Comment On: NRC-2025-0025-0001 List of Approved Spent Fuel Storage Casks: NAC International, Inc., NAC-UMS Universal Storage System, Certificate of Compliance No. 1015, Renewed Amendment No. 10, and Revision 1 to Renewed Amendment Nos. 5 through 9 Document: NRC-2025-0025-DRAFT-0001 Comment on FR Doc # 2025-22230 Submitter Information Email:savetheamericancommunities@gmail.com Organization:OBELISK TECH SYSTEMS INC. SUBMITTED BY CEO JAMES POOLE General Comment Attached is an executed, sworn analytical petition and comment submitted pursuant to the Administrative Procedure Act (5 U.S.C. §§ 553(e), 706), the Paperwork Reduction Act (44 U.S.C. §§ 3501-3521), the Regulatory Flexibility Act, and applicable OMB Circulars (A-4, A-11).

This filing documents statutory drift between the Atomic Energy Act, the Nuclear Waste Policy Act, and current NRC implementation across multiple provisions of 10 C.F.R. Parts 20, 50, 72, and 73; material understatement of compliance burden and economic cost; failure to consider less burdensome and technology-neutral alternatives; and conflicts with Executive Orders directing agencies to reduce regulatory waste, promote American innovation, and adopt performance-based regulation.

This submission is intended to be docketed, preserved, indexed, and transmitted to OMB/OIRA as part of the official administrative record and for purposes of agency reconsideration, PRA oversight, and potential judicial review.

Submitted by James Poole, CEO & Executive Chairman, Obelisk Tech Systems, Inc.

Executed January 5, 2026.

Attachments NRC-2025-0025-0001_Statutory-Drift_PRA-APA-Petition_Technology-Neutrality_Economic-Harm_Obelisk-Tech-Systems_Poole_Executed-2026-01-05.pdf 1/9/26, 5:17 PM blob:https://www.fdms.gov/0eb8dc06-e009-48d6-9fb1-c9006353b89a blob:https://www.fdms.gov/0eb8dc06-e009-48d6-9fb1-c9006353b89a 1/1

SWORN ANALYTICAL COMMENT AND PETITION FOR REGULATORY RECONSIDERATION Paperwork Reduction Act and Administrative Procedure Act Challenge Technology Neutrality, Economic Burden, and Compliance Overreach Re: NRC Proposed Rule - Spent Fuel Storage and Cask Certification Framework Docket No.: NRC-2025-0025-0001 Submitted pursuant to:

Paperwork Reduction Act (44 U.S.C. §§ 3501-3521)

Administrative Procedure Act (5 U.S.C. §§ 553(e), 706)

Regulatory Flexibility Act (5 U.S.C. §§ 601-612)

OMB Circular A-4 and A-11 Applicable Executive Orders on Regulatory Reform, Waste Reduction, and American Innovation

1. PURPOSE AND SCOPE This sworn submission is submitted for inclusion in the official administrative record to formally identify and preserve material legal, procedural, economic, and technological defects in the Nuclear Regulatory Commissions current and proposed regulatory framework governing spent nuclear fuel storage and cask certification.

Specifically, this submission:

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

Challenges NRC information-collection and compliance burdens under the Paperwork Reduction Act (44 U.S.C. §§ 3501-3521), including systematic and material understatement of real-world burden hours, compliance cost, and executive diversion; Petitions for regulatory reconsideration under 5 U.S.C. § 553(e), requesting revision of compliance structures that are outdated, unnecessarily burdensome, prescriptive rather than performance-based, and not technology-neutral; Documents material understatement of compliance burden, cost, and operational impact, including uncounted executive, engineering, legal, and opportunity costs that materially affect utilities, vendors, and the broader energy sector; Identifies the NRCs failure to meaningfully consider less burdensome, performance-based, and technology-neutral alternatives, as explicitly required by statute, OMB guidance, and Executive Branch policy; Requests corrective action, reconsideration, and formal oversight by OMB/OIRA, including resubmission of any affected information collections with corrected accounting and legally sufficient alternatives analysis.

This submission does not challenge nuclear safety objectives.

It challenges how safety is operationalized, how regulatory burden is measured, and whether lawful alternatives were considered, as required by the Paperwork Reduction Act, the Administrative Procedure Act, OMB Circular A-4, and binding Executive Orders governing regulatory policy.

STATUTORY AUTHORITY, CONTEXT, AND REGULATORY DRIFT Congressional Intent vs. Current NRC Implementation The NRCs authority to regulate spent nuclear fuel storage and cask systems arises from specific Acts of Congress, enacted with the express intent that nuclear safety regulation be:

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

Risk-informed Performance-based Technology-inclusive Continuously updated in light of advancing science and engineering Efficient and not unnecessarily burdensome The Commissions current CFR implementation departs materially from this intent.

ACTS OF CONGRESS PROVIDING AUTHORITY The NRCs relevant authority derives primarily from:

1. Atomic Energy Act of 1954 (AEA)

(42 U.S.C. §§ 2011-2297h)

Congressional intent:

Protect public health and safety Encourage development and utilization of nuclear technology Avoid unnecessary impediments to technological progress Key principle:

Safety regulation must evolve with scientific and technological advancement.

2. Energy Reorganization Act of 1974 BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

(42 U.S.C. §§ 5801-5891)

Congressional intent:

Separate promotion from regulation Ensure technically competent, risk-based oversight Maintain adaptability and expertise within NRC Key principle:

Regulation must remain technically rational and responsive, not ossified.

3. Nuclear Waste Policy Act of 1982 (NWPA)

(42 U.S.C. §§ 10101-10270)

Congressional intent:

Enable safe interim storage of spent nuclear fuel Avoid indefinite, unnecessarily costly temporary solutions Facilitate practical, secure storage pending permanent disposal Key principle:

Interim storage must be practical, flexible, and cost-effective, not administratively frozen.

4. Administrative Procedure Act (APA)

(5 U.S.C. §§ 551-706)

Congressional intent:

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Prevent agencies from maintaining irrational or outdated rules Require reasoned decision-making Mandate consideration of alternatives

5. Paperwork Reduction Act (PRA)

(44 U.S.C. §§ 3501-3521)

Congressional intent:

Minimize paperwork and compliance burden Prevent agencies from using paperwork as a control mechanism Require accurate accounting of real-world burden REGULATORY DRIFT CFR IMPLEMENTATION OUT OF CONTEXT While Title 10 CFR Parts 20, 50, 72, and 73 were promulgated under these Acts, the current implementation has drifted from congressional intent in the following ways:

Safety has become design-centric instead of performance-centric Compliance has become vendor-locked instead of technology-neutral Burden has become structural and perpetual instead of risk-proportionate Innovation has been procedurally excluded rather than evaluated BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

CFR requirements have become ends in themselves, not means to safety This drift is not authorized by Congress.

CFR-TO-STATUTE-TO-DEFECT MAPPING A. Mapping Table CFR Provision Enabling Statute Statutory Intent Current Defect Legal Failure Triggered 10 C.F.R. § 72.122 AEA /

NWPA Safe, practical interim storage Prescriptive design lock-in APA § 706(2)(A);

OMB A-4 10 C.F.R. § 72.212 AEA /

NWPA Flexible compliance Vendor-specific certificate dependency PRA § 3506 10 C.F.R. § 72.214 AEA /

NWPA Adaptive technology Closed approved-list model APA arbitrary action 10 C.F.R. § 72.236 AEA Performance safety Static design assumptions PRA § 3506(c)(3)(C)

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

10 C.F.R. § 72.238 AEA Efficient certification One-time approval rigidity OMB A-4 alternatives 10 C.F.R. § 50.59 AEA Encourage safe innovation Change deterrence APA irrationality 10 C.F.R. § 50.36 AEA Operational safety Checklist surveillance bias PRA undercounting 10 C.F.R. § 73.55 AEA Secure protection Prescriptive security without analytics OMB A-4 cost failure 10 C.F.R. § 73.51 AEA Fuel protection Static physical barrier reliance Failure to modernize 10 C.F.R. § 20.1101 AEA Radiation protection Documentation over performance PRA burden defect IV. CORE FINDING STATUTORY MISALIGNMENT The NRCs continued reliance on these CFR provisions as currently implemented results in:

Regulation divorced from congressional purpose BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

Compliance burden not contemplated by statute Innovation suppression not authorized by Congress Paperwork functioning as a control mechanism rather than safety support Under the APA, agencies may not continue to enforce regulatory structures that have become irrational or misaligned with statutory intent.

V. LEGAL CONSEQUENCE Because the NRCs CFR framework has drifted beyond its statutory foundation:

PRA approvals are legally vulnerable Burden estimates are invalid Alternatives analysis is deficient OMB/OIRA review is mandatory Continued enforcement risks judicial reversal

2. FOUNDATIONAL PREMISE

1. 10 C.F.R. § 72.122 Overall Requirements (ISFSI Design Criteria)

This section embeds prescriptive design and operational requirements for spent fuel storage installations that:

Emphasize fixed structural assumptions Do not contemplate adaptive or real-time safety verification BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

Assume safety through design permanence rather than continuous performance Defect:

By privileging static design compliance over measurable performance outcomes, § 72.122 discourages continuous sensing, analytics, and condition-based safety verification.

Legal impact:

Violates OMB Circular A-4 by failing to consider less burdensome, performance-based alternatives.

2. 10 C.F.R. § 72.212 Conditions of General License This provision requires licensees to strictly adhere to certificate-specific conditions tied to approved cask designs.

Defect:

Safety compliance becomes inseparable from specific vendor certificates, effectively prohibiting third-party or independent monitoring technologies unless explicitly approved within the certificate.

Legal impact:

Creates vendor lock-in and artificially inflates compliance burden, implicating 44 U.S.C. § 3506(c)(1)(A).

3. 10 C.F.R. § 72.214 List of Approved Spent Fuel Storage Casks This section codifies a closed list of approved cask designs, updated through slow, resource-intensive rulemaking.

Defect:

Innovation is gated not by safety performance, but by inclusion on a regulatory list, creating multi-year technology lag.

Legal impact:

Maintenance of this structure without technology-neutral alternatives is arbitrary and capricious under APA § 706(2)(A).

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

4. 10 C.F.R. § 72.236 Specific Requirements for Storage Cask Approval This section requires compliance with highly prescriptive criteria tied to design assumptions at the time of certification.

Defect:

The rule assumes static conditions and does not allow modular or incremental safety upgrades without full recertification.

Legal impact:

Fails to consider less burdensome alternatives under 44 U.S.C. § 3506(c)(3)(C).

5. 10 C.F.R. § 72.238 Issuance of Certificates of Compliance This provision establishes a certification process that is:

Time-intensive Design-centric Resistant to iterative improvement Defect:

The certification model treats safety as a one-time approval rather than a continuously verifiable condition.

Legal impact:

Contrary to risk-informed regulation principles and inconsistent with OMB Circular A-4.

6. 10 C.F.R. § 50.59 Changes, Tests, and Experiments This section severely restricts changes to licensed configurations without extensive analysis and approval.

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

Defect:

Even safety-enhancing monitoring or analytics upgrades can trigger regulatory friction, discouraging adoption.

Legal impact:

Creates regulatory inertia inconsistent with modern safety engineering and violates APA rationality standards.

7. 10 C.F.R. § 50.36 Technical Specifications Technical Specifications impose rigid operational limits and surveillance requirements.

Defect:

Surveillance is treated as periodic and checklist-based, rather than continuous and data-driven.

Legal impact:

Fails to account for technological evolution, rendering continued reliance arbitrary under APA

§ 706.

8. 10 C.F.R. § 73.55 Physical Protection Requirements This section mandates prescriptive security measures.

Defect:

Security compliance is decoupled from real-time situational awareness and advanced analytics, despite availability.

Legal impact:

Exclusion of modern monitoring alternatives increases cost and risk, violating OMB Circular A-4 cost-benefit requirements.

9. 10 C.F.R. § 73.51 Protection of Spent Nuclear Fuel This provision emphasizes physical barriers and procedural controls.

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

Defect:

Fails to integrate continuous monitoring, anomaly detection, or data fusion as core safety elements.

Legal impact:

Reinforces outdated compliance assumptions and ignores less burdensome alternatives.

10. 10 C.F.R. § 20.1101 Radiation Protection Programs This section requires formal programs but does not mandate or incentivize real-time measurement and analytics.

Defect:

Compliance is documentation-centric rather than performance-centric.

Legal impact:

Understates actual labor burden and opportunity cost in violation of PRA § 3506.

SYSTEMIC EFFECT OF CFR-LEVEL DEFECTS Taken together, these provisions:

Embed static, design-centric safety assumptions Produce vendor-locked compliance pathways Inflate paperwork and governance burden Exclude independent and innovative technologies Create regulatory lag measured in decades This architecture cannot be justified under modern PRA, APA, or OMB standards.

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

LEGAL CONCLUSION The NRCs continued reliance on this CFR structure, without meaningful reassessment or modernization, constitutes:

Material PRA noncompliance Arbitrary and capricious agency action Failure to consider less burdensome alternatives Violation of Executive Branch regulatory policy Corrective action is required.

NRC CASK REGULATION HAS EVOLVED INTO A CLOSED COMPLIANCE ECOSYSTEM The NRCs current approach to spent fuel storage and cask compliance no longer functions as a modern, risk-informed, performance-based safety framework.

Instead, it has evolved into a closed, vendor-dependent compliance ecosystem characterized by:

Prescriptive design lock-in, rather than outcome-based or performance-oriented safety objectives; Static certification models that assume technological stasis over multi-decade time horizons; Legacy monitoring assumptions developed prior to modern advances in real-time sensing, data analytics, cybersecurity, and anomaly detection; Systematic exclusion of independent, third-party monitoring and analytics technologies, regardless of demonstrated safety benefit; BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

Artificial barriers to market entry and innovation that are unrelated to actual risk reduction or safety outcomes.

This structure conflates safety with vendor compliance, transforming regulation into de facto market control rather than risk mitigation. The result is inflated compliance cost, suppressed innovation, and reduced system resilience, without commensurate improvement in public safety.

Such a regulatory posture violates:

OMB Circular A-4, which requires agencies to identify and evaluate reasonable regulatory alternatives and to account for indirect, opportunity, and behavioral costs; The Paperwork Reduction Act, which mandates minimization of information-collection burden and accurate accounting of real-world compliance workflows; The Administrative Procedure Act, by maintaining regulatory frameworks that are arbitrary, outdated, and irrational in light of current technological realities.

3. PRA FAILURES MATERIAL BURDEN UNDERSTATEMENT The NRCs Paperwork Reduction Act burden estimates materially understate actual compliance burden by excluding entire categories of real-world labor, cost, and operational impact.

Specifically, NRC PRA accounting fails to include, at a minimum:

Executive, engineering, legal, and compliance labor required to maintain certification status over time; Repeated documentation, audit-support, surveillance, and re-certification cycles driven by static certification assumptions; BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

Third-party vendor dependency costs imposed by prescriptive design and monitoring requirements; Opportunity costs arising from delayed deployment, delayed modernization, and foregone innovation; Exclusion of competitive, independent monitoring and analytics technologies that would materially reduce burden and improve safety transparency.

These omissions violate 44 U.S.C. § 3506(c)(1)(A), which requires agencies to provide accurate, realistic, and complete estimates of the burden imposed by information collections.

A burden estimate that excludes executive time, opportunity cost, and structural dependency effects is not merely inaccurate it is legally deficient.

4. FAILURE TO CONSIDER LESS BURDENSOME ALTERNATIVES The NRC has failed to meaningfully evaluate, document, or respond to less burdensome alternatives, including but not limited to:

Performance-based safety standards focused on measurable outcomes rather than prescriptive design mandates; Technology-neutral monitoring requirements allowing multiple lawful compliance pathways; Continuous sensing and analytics models as alternatives to inspection-only regimes; Independent anomaly detection and condition-based monitoring systems; Modular, incremental, or conditional certification updates rather than full recertification cycles.

This failure violates:

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

44 U.S.C. § 3506(c)(3)(C) (requirement to evaluate less burdensome alternatives);

OMB Circular A-4 (requirement to assess reasonable regulatory alternatives and indirect costs);

APA procedural requirements, rendering the framework legally vulnerable.

An agency may not lawfully maintain a burdensome regulatory structure without demonstrating that less burdensome alternatives were considered and rejected on the merits.

5. TECHNOLOGY EXCLUSION & VENDOR LOCK-IN The NRCs current framework has the practical effect of:

Privileging incumbent cask and service vendors through prescriptive compliance structures; Excluding third-party safety monitoring, sensing, and analytics innovation; Discouraging American startups and advanced-technology entrants from participating in the nuclear safety market; Increasing cost, fragility, and dependency, while reducing transparency and redundancy.

A safety regime that prevents adoption of safer, more transparent, and more resilient technology is neither rational nor lawful.

Regulation that blocks innovation without safety justification constitutes regulatory waste and abuse.

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

6. ECONOMIC & NATIONAL IMPACT The NRCs failure to account for indirect and opportunity costs masks substantial national harm, including:

Higher compliance costs passed through to utilities and ratepayers, increasing energy costs and reducing economic efficiency; Suppressed innovation in nuclear safety, sensing, analytics, and monitoring technologies; Loss of high-skill engineering, analytics, and manufacturing jobs that would otherwise be created by competitive technology adoption; Reduced system resilience, due to reliance on static, vendor-locked monitoring assumptions; National security risk, arising from lack of independent verification, redundancy, and real-time situational awareness.

Under OMB Circular A-4, these indirect, behavioral, and opportunity costs are mandatory components of regulatory analysis and may not be ignored.

A regulatory framework that destroys jobs, suppresses innovation, and increases cost without proportional safety benefit is not merely inefficient it is unlawful.

7. EXECUTIVE ORDER CONFLICTS ECONOMIC HARM, JOB LOSS, AND NATIONAL WASTE The NRCs current and proposed regulatory framework directly conflicts with binding Executive Branch policy as articulated in multiple Executive Orders directing federal agencies to reduce unnecessary regulatory burden, eliminate waste and abuse, and promote American innovation and competitiveness.

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

Specifically, Executive Orders require agencies to:

Reduce unnecessary, duplicative, and outdated regulatory requirements that impose cost without proportional public benefit; Eliminate regulatory waste, inefficiency, and artificial barriers to market entry; Promote American technological leadership, domestic manufacturing, and high-skill job creation; Adopt performance-based, technology-neutral regulatory frameworks rather than prescriptive design mandates.

The NRCs existing approach violates these directives by maintaining a static, vendor-dependent compliance architecture that:

Artificially inflates compliance costs without demonstrable safety gains; Suppresses job creation in advanced sensing, analytics, cybersecurity, and monitoring sectors; Forces utilities and operators to divert capital from modernization, hiring, and innovation into repetitive, low-value compliance activities; Discourages domestic startups and small businesses from entering the nuclear safety and monitoring market; Locks in legacy vendors, concentrating economic benefit while excluding competitive American technologies.

Economic Damage and Job Loss The NRCs failure to adopt technology-neutral and performance-based standards results in:

Lost high-skill engineering, software, analytics, and systems jobs that would otherwise be created through competitive monitoring and safety innovation; BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

Suppressed domestic investment in nuclear-adjacent safety technologies; Higher energy costs passed to ratepayers, reducing disposable income and economic activity; Reduced workforce resilience, as compliance spending replaces productive labor investment.

Conversely, adoption of modern, technology-neutral frameworks would:

Create and preserve high-wage American jobs in engineering, data science, cybersecurity, and advanced manufacturing; Reduce long-term compliance costs, freeing capital for hiring and infrastructure; Increase system resilience and safety transparency through independent verification and redundancy; Strengthen national security by reducing reliance on static, opaque compliance models.

Failure to align with Executive Orders therefore constitutes policy noncompliance, economic mismanagement, and avoidable national waste, subject to correction and review by OMB/OIRA.

8. APA VIOLATIONS ARBITRARY MAINTENANCE OF OUTDATED REGULATORY STRUCTURES Maintaining the current NRC framework constitutes unlawful agency action under the Administrative Procedure Act.

Specifically, the NRCs approach is:

Arbitrary and capricious under 5 U.S.C. § 706(2)(A), as it persists in outdated compliance structures despite the availability of demonstrably superior BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

technologies; Internally inconsistent with the NRCs stated commitment to risk-informed, performance-based regulation; Unsupported by current technological and economic realities, including real-time sensing, advanced analytics, and anomaly detection; Procedurally defective under § 706(2)(D) due to failure to observe required analytical procedures, including meaningful evaluation of alternatives and full cost accounting.

An agency may not lawfully preserve a regulatory framework simply because it is familiar or entrenched, particularly where that framework imposes excessive cost, suppresses innovation, and undermines stated policy objectives.

9. REQUESTED RELIEF CORRECTIVE ACTION AND MODERNIZATION Petitioner respectfully requests that the Nuclear Regulatory Commission and the Office of Management and Budget:

1. Correct PRA burden estimates to reflect actual executive, engineering, compliance, and opportunity costs;

2. Adopt technology-neutral, performance-based safety standards that focus on outcomes rather than prescriptive designs;

3. Reevaluate certification and monitoring frameworks in light of modern sensing, analytics, and verification technologies;

4. Permit independent monitoring, sensing, and analytics technologies as lawful compliance alternatives; BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

5. Resubmit affected information collections to OMB/OIRA with corrected accounting, as required by law;

6. Provide a formal written response under 5 U.S.C. § 553(e) addressing the substance of this petition.

10. RECORDATION AND TRANSMITTAL DEMAND Pursuant to the Federal Records Act (44 U.S.C. §§ 3101-3106), this submission constitutes an official agency record and must be:

Docketed in the applicable rulemaking record;

Preserved without alteration or omission;

Indexed for future review and judicial consideration;

Transmitted to OMB/OIRA as part of the official oversight and compliance record.

Failure to properly record, preserve, or transmit this submission constitutes a procedural defect under APA § 706(2)(D) and undermines the integrity of the administrative process.

11. SIGNATURE AND DECLARATION I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information, and belief.

Executed: January 5, 2026 James Poole Chief Executive Officer & Executive Chairman Obelisk Tech Systems, Inc.

01/06/2026 BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80

BoldSign Document ID: 4ea2bdb4-6661-4f97-837d-e8879f6a9b80