# Project Stratus Permits Sequencing and Stormwater
Internal City of Conway and Conway Development Corporation correspondence on Project Stratus permits and stormwater coordination, January through June 2025. **The single most consequential record in this production for the developer-overlap question: it establishes [[EMH&T]] (Columbus, Ohio civil engineering, surveying, planning) as Project Stratus's site-civil engineer — the same firm of record on [[Project Boar Site Survey|Project Boar]]**. Per [[T003 - Shell-LLC Principal Attribution for Forgelight and Willowbend|T003]] / [[D003 Synthesis]] the "three Tier-1 channels" standard for promoting Tier-3 attribution to Tier-1; the Forgelight↔Willowbend developer overlap now has two correspondence-based shared-vendor channels — shared counsel ([[Kutak Rock LLP]]) and shared civil engineer (EMH&T).
## What's inside
- `RE_ Project Stratus Stormwater Call Request.pdf` — email thread from January 21–28, 2025 between EMH&T (Robert McCurnin, Mariah Anderson PE, Mackenzie Hebert) and City of Conway (Kurt Jones P.E., Felicia Rogers) and CDC (Corey Parks) on stormwater drainage criteria for the Project Stratus site.
- `RE_ Project Stratus Stormwater Call Request_I.pdf` — companion/follow-on to the above, same thread.
- `Project Stratus Required Permits - Response Needed by 6.20.25.pdf` — email from Corey Parks (CDC) to Anne Tucker and Kurt Jones (City), dated June 17, 2025, requesting input on the Stratus permitting timeline at the request of a Forgelight subcontractor. Attaches `Project Stratus Permitting 6.17.25.xlsx` (not in this production — Excel attachment).
- `Re_ Project Stratus Required Permits - Response Needed by 6.20.25.pdf` — reply thread to the above.
- `Project Stratus Next Steps and Sequence.pdf` — Jamie Gates's April 1, 2025 sequencing memo (covered separately by [[Project Stratus MOU and April 1 Special Council Meeting]] but also referenced here for the permits sequencing it previewed).
## Key takeaways
- **EMH&T is Project Stratus's site-civil engineer.** The stormwater email thread shows EMH&T's Mariah Anderson, PE (Senior Engineer, Water Resources, 5500 New Albany Road, Columbus, OH 43054,
[email protected]), Robert McCurnin (
[email protected]), and Mackenzie Hebert (
[email protected]) coordinating directly with Conway Corporation's stormwater authority (Kurt Jones, Transportation Department) on Project Stratus drainage design. **The same EMH&T (same Columbus address, same firm) is the engineering client of the ALTA/NSPS Survey for [[Project Boar Site Survey|Project Boar]] at the Port of Little Rock**, per the [[2026-05 Little Rock Port Authority Produces Project Boar Records|Bryan Day production]] of 2026-05-26. EMH&T's appearance on both projects is a second Tier-1 correspondence-based shared-vendor channel between Forgelight (Conway) and Willowbend (Port of Little Rock).
- **The earliest Stratus reference in the production: 2025-01-21.** Robert McCurnin's January 21, 2025 email to Kurt Jones (`RE_ Project Stratus Stormwater Call Request.pdf` p. 3) is the earliest-dated "Project Stratus" reference in this corpus, predating the April 1, 2025 MOU by ~10 weeks. This is consistent with [[The Conway Data Center Project]]'s open question on when "Forgelight" and "Conway" first met — the answer (per the [[April 2026 FAQ Project Stratus|FAQ]]: Entergy site-selection) was that the company had already chosen Conway by early 2025.
- **The stormwater technical posture.** Kurt Jones (City) tells McCurnin (EMH&T): "The section of the Drainage Criteria Manual that addresses conditions that warrant a waiver for detention is 7.2 (second paragraph). Though not specifically stated in the Drainage Criteria Manual, our policy has historically been to grant a waiver in situations where the development directly borders a FEMA regulated flood hazard area" (`RE_ Project Stratus Stormwater Call Request.pdf` p. 2). Site borders C.L. Tucker Creek and the Arkansas River floodplain — a FEMA regulated area. **The City is signaling pre-application that a detention-waiver is on the table for Project Stratus**, citing historical practice rather than written policy.
- **Spillway / freeboard understanding.** "I don't have an issue with the emergency spillway being utilized as a control for the 2–100-year flows if the freeboard requirement is met. In other words, 1 foot of spillway depth should be provided above the 100-year water surface elevation" (`RE_ Project Stratus Stormwater Call Request.pdf` p. 2, Kurt Jones to EMH&T).
- **The Stratus subcontractor on permitting.** "We are following up on a recent request from one of their subcontractors. They've asked us to help buildout their permitting timeline for their client's decision matrix" (`Project Stratus Required Permits.pdf` p. 1, Corey Parks to Anne Tucker / Kurt Jones, June 17 2025). "Their" = Forgelight Ventures. "Their subcontractors" = an unidentified development consultant working a "decision matrix" — likely either EMH&T or a separate hyperscale-projects consultant. The decision matrix is a typical hyperscale-developer tool for go/no-go gating across multiple candidate sites.
- **The "Conway Compass" reference.** "Using the current 'Conway Compass' article 10 draft table as a foundation, we made the attached spreadsheet" (`Project Stratus Required Permits.pdf` p. 1). "Conway Compass" is Conway's long-range planning document; article 10 governs permitting timelines. Not in the corpus; a public Conway record.
- **Time-constraint disclosure.** "[W]e've shared with them that the biggest time constraints in development review are statutory requirements and responding to staff comments" (`Project Stratus Required Permits.pdf` p. 1). CDC framing the City's permitting profile to Forgelight's subcontractor.
## People and orgs mentioned
- [[EMH&T]] — Columbus OH civil engineering firm; Project Stratus's site-civil engineer.
- Mariah Anderson, PE — EMH&T Senior Engineer, Water Resources.
- Robert McCurnin — EMH&T planning lead on Stratus.
- Mackenzie Hebert — EMH&T.
- [[Kurt Jones]] — City of Conway Transportation Department; Project Stratus stormwater counterparty.
- [[Anne Tucker]] — City Planning staff; permitting matrix counterparty.
- [[Felicia Rogers]] — Chief of Staff, Office of the Mayor.
- [[Corey Parks]] — Chief Economic Development Officer, [[Conway Development Corporation]] / [[Conway Area Chamber of Commerce]]; primary Stratus coordinator on the developer side.
- "Their subcontractors" — unidentified Forgelight consultant working a permitting decision matrix.
## Concepts invoked
- Conway Drainage Criteria Manual § 7.2 — detention-waiver authority.
- FEMA-regulated flood hazard area — the C.L. Tucker Creek / Arkansas River floodplain context for the Project Stratus site.
- Conway Compass — Conway's long-range plan, Article 10 covering permitting timelines.
- "Decision matrix" — hyperscale developer site-selection tool.
## Events documented
- 2025-01-21 EMH&T-Conway stormwater call request (earliest Stratus reference in corpus).
- 2025-06-17 Corey Parks request for permits matrix.
## Cross-references
- [[EMH&T]] — entity page; the Project Boar connection.
- [[2026-05 Little Rock Port Authority Produces Project Boar Records]] — the production where EMH&T first surfaced in the corpus.
- [[T003 - Shell-LLC Principal Attribution for Forgelight and Willowbend]] — the EMH&T finding is a new Tier-1 channel for the Forgelight↔Willowbend overlap question; the D003 verdict standard requires ~three channels. Two are now documented (shared counsel + shared engineer).
- [[Project Stratus MOU and April 1 Special Council Meeting]] — Jamie Gates's sequencing memo previewed the permits/IRB process.
- [[April 2026 FAQ Project Stratus]] — the FAQ confirms Entergy as the site-selection partner, framing the early-2025 stormwater contacts.
## Open questions / follow-ups
- The `Project Stratus Permitting 6.17.25.xlsx` attachment (the permitting spreadsheet itself) is not in this production. The reply asks the City to confirm whether it was overlooked in the export or withheld.
- The identity of "their subcontractors" requesting the permitting decision matrix is not in the production. A follow-on FOIA could ask CDC or the City to name the consultant.
- The Conway Drainage Criteria Manual is a public Conway document; archiving the relevant § 7.2 text would Tier-2-anchor the regulatory framework.
- The downstream stormwater design itself (after the January 2025 call) is not in the production; that engineering work is presumably being conducted by EMH&T for Forgelight, paid for by the Company per the MOU.