# 2025-10 DEQ Pre-Application Meeting with AVAIO On 2025-10-30, DEQ's Office of Air Quality met with AVAIO about backup generators for the Project Leo data center — the earliest documented Arkansas air-permitting contact for the site. Per [[Demetria Kimbrough]] (2026-02-09): "we did meet with the facility on 10.30.25. During that meeting the facility provided that they would install **62 emergency diesel backup generators** and be subject to NESHAP 4Z and NSPS 4I." Attendees: "facility representatives Joe Hubbard and Tom Nesel as well as consultants from Trinity"; DEQ side per AVAIO's later account: Erika Droke, Demetria Kimbrough, Thomas Rheaume. ## Sources - ([[AVAIO Emergency Generator Pre-Permitting Correspondence]], `Re_ questions re_ emergency generators…Outlook1.pdf`, p. 1; `…Outlook2.pdf`, p. 1) - ([[AVAIO Tier 4 Equivalent Email to the Commerce Secretary]], `260305-email.pdf`, p. 3 — "A Pre-app was held 10/30 w/ Erika Droke, Demetria Kimbrough, and Thomas Rheaume.") ## What happened AVAIO disclosed a 62-unit emergency-diesel fleet and the expected rule framework (NESHAP ZZZZ / NSPS IIII). No application was filed; the meeting seeded the February–March 2026 "Tier 4 equivalent" negotiation. ## Significance Fixes the Leo backup-fleet number (62 × 3 MW ≈ 186 MW) at Tier 1, predating any public filing — and timestamps how early AVAIO was shaping the "emergency" classification that its later ESA-curtailment argument depends on.