# Groot Air Permit Pre-Draft Correspondence The working correspondence file behind the issued [[Project Pyramid Title V Air Permit (2507-AOP-R0)]]: `Binder1.pdf` (114 pages) plus the overlapping prints `Correspondence2.pdf`, `Correspondence3.pdf`, `Correspondence4.pdf`. October 2025 – February 2026, between DEQ Office of Air Quality engineer [[Shawn Hutchings]] and [[GROOT LLC]]'s air consultants at [[Olsson]] (Jim Timmons, Cassie Johnson) — with **[[David Essex]], a `[email protected]` address, CC'd throughout the November 2025 pre-draft review**. ## Key takeaways 1. **DEQ refused to draft the permit until Groot's ownership disclosure named someone.** Hutchings, 2025-10-20: "That disclosure still does not list anyone as officers or owners of Groot LLC. The disclosure statement issue will need to be addressed before we can issue a draft permit" (`Binder1.pdf`, printed p. 26). In the same message he rejected the application's signature: "The application was signed by someone stating they are delegated with a delegation letter **they signed themselves**. They must be delegated by a responsible official." The fix accepted ten days later: "Both titles apply to Michael Montfort but the signed pages submitted to correct the disclosure statement lists his title as 'Manager/Officer.' **Manager will suffice**" (Johnson/Hutchings, 2025-10-30). The permit's responsible-official identity thus resolved to [[Michael Montfort]] — the [[Wilson Sonsini Goodrich & Rosati]] attorney — as "Manager." 2. **The substantive engine data is confidential.** Hutchings, 2025-11-03: "Because **sizes, and what they power are only in the confidential application**, I am asking about the two engines that you list with 17.68 lb/hr of NOx" — a Tier-1 statement that the public application redacts engine sizes and served loads. 3. **A site-wide synthetic-minor NOx cap was negotiated**: Olsson requested "a combined, site-wide emission limit of **249 tpy of NOx** emissions for all generators over any consecutive 12-month period" (Timmons, 2025-10-14) — one ton under the 250-tpy PSD major-source threshold, the same architecture AVAIO proposes for Leo and Rankin. 4. **A Google employee sits inside the named-entity's permit file.** David Essex (`[email protected]`) is CC'd on the pre-draft review traffic (Nov 6–12, 2025) alongside Olsson and DEQ. Groot's association with [[Google LLC]] is already independently established in this corpus; this is the first DEQ-channel record of Google personnel participating in Groot's air permitting. **It does not bear on the bracketed shells** (Forgelight / Willowbend / Spark) and does not trip the [[T003 - Shell-LLC Principal Attribution for Forgelight and Willowbend|T003]] un-bracketing condition. 5. **Permit mechanics documented**: pre-draft issued 2025-11-04 ("the paper for public notices only publishes on Sunday"); ERT/HAP-calculation corrections through October (belly-tank HAPs, Tier 3-vs-Tier 2 applicability for two 17.68 lb/hr units); cooling-tower conditions (TDS ≤ 1,500 ppm, semiannual testing — Specific Conditions 56–57); and the February 2026 plan for construction-commencement notifications under Section VI, Condition 1. ## What's inside - `Binder1.pdf` — the compiled DEQ↔Olsson file (threads: "Groot LLC Air Permit Application/Permit," "Pre-Draft Air Permit," "2507-AOP-R0 Initial Notifications"). - `Correspondence2.pdf` / `Correspondence3.pdf` — October 2025 prints of the same application/permit thread (Mazurkiewicz/Hutchings/Timmons; partially font-garbled in extraction — re-OCR if cited beyond what is quoted here). - `Correspondence4.pdf` — Rheaume's 2025-10-06 internal forward of the initial Olsson inquiry. ## People and orgs mentioned - [[Shawn Hutchings]]; John Mazurkiewicz, Golly Easterly, Thomas Rheaume, Heinz Braun (DEQ); [[Olsson]] (Jim Timmons, Cassie Johnson); [[David Essex]] ([[Google LLC]]); [[Michael Montfort]]; [[GROOT LLC]]. ## Concepts invoked - Synthetic minor / PSD avoidance (the 249-tpy cap); Title V; disclosure-statement requirements (Ark. permit practice). ## Cross-references - [[Project Pyramid Title V Air Permit (2507-AOP-R0)]] — the permit this file produced. - [[T003 - Shell-LLC Principal Attribution for Forgelight and Willowbend]] — new input recorded (state pressure on shell opacity; Montfort title resolution; Google employee in the file); status unchanged. - [[AVAIO Emergency Generator Pre-Permitting Correspondence]] — the same DEQ office walking the same synthetic-minor path with AVAIO. ## Open questions / follow-ups - The "confidential application" — whether the unredacted engine schedule is obtainable under § 25-19-105(f)(3) or via a confidentiality-justification challenge. - Heinz Braun (compliance) — first appearance; the initial-notifications track moves to compliance as construction begins.