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Audits

Corpus completeness audit — what source documents are missing

Audited 2026-06-06. Scope: every collection under data/documents/ cross-referenced against the corpus’s own declared expectations — the PRR production tracker, the minutes manifest, the PRR-01 bundle index, and the provenance citations inside data/extracted/.

Method: (1) Substantive gaps read from the county’s own item-by-item response in bosc-prr-production-2026-06-05.response-index.yaml — i.e. records requested and not produced, not inference. (2) Integrity gaps computed by script: minutes/agenda filename parsing + pairing over commissioners/minutes/raw/, existence-checks of every *.pdf cited across extracted/**, and the PRR-01 bundle’s derived_files. Ambiguous date-typo filenames were not auto-resolved (the heuristic produced impossible dates); they are listed for human verification. Minutes findings reflect the 2026-04-17 manifest snapshot, not today.

Integrity pass now automated. The mechanical half — existence + freshness across every catalogued dataset — is regenerated from the data catalog by watermark catalog audit into data/catalog/COMPLETENESS.md and gated against drift by watermark catalog check. This document keeps the substantive half (records an authority withheld), which is human judgment, not a script.

Headline

The archive itself is in good shape; what’s “missing” is mostly what the county hasn’t produced. Provenance is clean (94 distinct source PDFs cited across the extractions, 0 genuinely absent). The PRR production binaries are all present. The substantive holes are the records the county deferred or withheld — above all the entire county-wastewater engineering universe (PRR items 5–15) and the item-4 cost-benefit analysis — plus a modest set of corpus-hygiene issues in the minutes series (publication lag + ~12 malformed/misfiled filenames), none of which indicate lost evidence. A separate, newer thread (§2) tracks watershed/conservation grant docs worth digging up — the primary instruments behind a $650k Lost Creek (Maumee-headwater) ag-runoff grant whose SWCD summary is now in the corpus. A third thread (§4) tracked the OEPA air permit P0138965 — the secondhand-cited keystone behind the disclosed 313 MW power figure, and the expected source of the three-hall building footprint — which has now been ingested (2026-06-15): the 2026-05-28 final PTI (eDoc 4132514) confirms the genset count and three-hall emission-unit grouping on a primary footing, though the per-engine ekW behind 313 MW remains trade-secret-redacted (see §4). A fourth thread (§5) tracks the grid/interconnection side the air permit itself punted to PUCO/the utility — AEP Ohio’s Lyka Transmission Project (345kV substation + line) — ingested 2026-07-11: a direct search of opsb.ohio.gov and AEP’s own regulatory-filings index found no OPSB case filed as of 2026-07-11 — consistent with AEP’s own fact sheet, which places the planned filing at Early 2027 — and the Google/Bistrozzi customer attribution stays [inference] pending that filing (see §5). A new City of Lima track (§1) opens the campaign’s first municipal-utility custodian (#1536): the one load-bearing City record needing no records request — the Lima WWTP’s own NPDES permit + design flow (2PE00000 / OH0026069, previously absent from the corpus) — was pulled from the public record 2026-07-14, counting the 18.5 MGD municipal design flow into the routed water balance (the Ottawa leaving Lima now computes 98% treated effluent); the water-supply agreement, the $13.6M infrastructure allocation, and the sewer/pretreatment records required the request — which has since been served, drawing a partial response on 2026-08-22/24 that answered 4 of 11 items and left 7 unanswered with no exemption asserted (see §1).

Publishing vs. holding. What the corpus contains (this audit) is separate from what the public site serves. Every source document is default-deny on the public surface until a document publication review (epic #274; review checklist #281) clears its rel for the publish allowlist (#280) — a PII/legal-status pass, not byte redaction (chain of custody is immutable).


1. Substantively missing — records the county has NOT produced

Declared in the county’s first production tracker (cover letter 2026-06-05, Clerk of Board Brittany N. Woods). Of the 19-item request, these remain outstanding:

Item(s)CategoryWhat’s owedCounty’s stated posture
5–15County wastewater worksBOSC pump-station/forcemain procurement; Shawnee II Phase 2; Shawnee Oaks / Hamlet of Hume sewering; permits DSWPTI-260294 & DSW-6756; 1996 CWA consent decree; Cridersville WWTP recordsProduced 2026-06-12 (batch 2) — BOSC CMAR chain (#469-25→#137-26→#378-26), data-center-flows TO5 (#679-24), Shawnee Oaks (#113-26/#136-26), Hume (#135-26), Shawnee II Phase 2 (#220-24/#937-23). Outstanding = construction bids/award only (the CMAR is still at pre-construction). The other named items are already in-corpus: permits DSWPTI-260294 + DSW-6756 (data/extracted/permits/ 4074527/4074529/4074551, approved 2026-04-07, BOSC-1A private sanitary sewer); the 1996 CWA consent decree (regulatory/wastewater-enforcement-history.yaml — Civil Action 3:96 CV 7134, + source PDF); and Cridersville WWTP (NPDES OH0020222, 2.4 MGD → Little Ottawa, in the EPA ECHO inventory, now linked to the reroute economics in sanitary-economics.yaml). Batch 3 (2026-07-24) — the Sanitary Engineer’s per-item native file trees for items 9/11/13/14/15 (1,610 files / ~1.04 GB: the SSO/SECAP/DFFO enforcement record incl. the 2023 Shawnee II DFFO extension letter, Loan 6718 financing, the Hume Road WPCLF application, the Cridersville/Shawnee Oaks reroute file) — custody + posture in prr-mandamus/bosc-prr-production-2026-07-24.response-index.yaml; item-by-item audit in bosc-prr-production-2026-07-24.analysis.md. Adequacy sweep done (all 1,245 machine-readable files): item 9’s 12.6 MGD Phase-2 record was not produced (0 hits) and item 13’s empty “13 - See 9” folder is a constructive denial (the referenced item-9 tree is Phase-1-era 2008–2016, no 2024→ MS Consultants / BOSC records); item 11’s Hume Road WPCLF application carries no feasibility study or forcemain-MGD across all 11 pages. Still outstanding after batch 3: item-4 cost-benefit, the 12.6 MGD / forcemain-MGD figures, and the corridor environmental-permit layer.
4Project BOSCCost-benefit analysis / projected tax-revenue impact / public-ROI inputs & assumptionsWithheld “being reviewed by our legal counsel for compliance with R.C. 149.43 and R.C. 9.66.” Not produced.
2Project BOSCCounty ⇄ DoD / federal-contractor (GDIT, GDLS) comms re the American Twp facility / corridor”No records”; county narrowed the ask. Deemed fulfilled.
16WebsiteCMS audit trail / edit history for the Sanitary Engineering pages, 2025-01-01→“No records… do not manage the county website.” Contested — WordPress revision history exists behind a 401 gate (see below).
17WebsiteInternal comms re adding/removing BOSC / RFP / Bistrozzi / Shawnee II references on county sites”No responsive records.”
18AddressRecords indexed to 4110 N. Cole St., Lima not caught by entity/project name”No responsive records” (partial).
19Engineer of recordCounty ⇄ EMH&T commsNone as to Commissioners; may supplement from Sanitary Eng.

The Category-B deferral — once the largest hole — was produced 2026-06-12 (batch 2; item-by-item in prr-mandamus/bosc-prr-production-2026-06-12.response-index.yaml). The production also resolved a corpus discrepancy: resolutions #113-26 / #135-26 / #136-26 had been mislabeled “forcemain feasibility” — the primary records show #113-26 = Shawnee Oaks engineering (Access, $161k), #135-26 = Hamlet of Hume WPCLF ($2.0M), #136-26 = unincorporated Shawnee Twp / Shawnee Oaks WPCLF ($1.6M). These records tie to the OEPA Shawnee II permit 2PK00002 in data/extracted/oepa/ and the ECHO discharger inventory in data/reference/echo/. They also yield the data-center → WWTP keystone (Task Order #5, #679-24 — a “Data Center Flows Treatment Evaluation” of the campus blowdown stream).

Item 16 is “missing” by custody disclaimer, not non-existence. The response index’s own rebuttal shows the Sanitary pages’ WordPress modified dates fall inside the requested window and the /revisions endpoint returns HTTP 401 (gated, not 404) — the version history exists; the county simply disclaims holding it. Custody sits with the host (AhelioTech / CorpComm-built site) — see allen-county-web-vendor-audit.md and allen-county-level-sites.md.

Universe note: per the relator’s 2026-06-03 narrowing email, any request item not listed was treated as withdrawn — so the “owed” set is bounded by these items. Production is rolling (“every Friday”). Items 5–15 were produced in batch 2 (2026-06-12), and batch 3 (2026-07-24) added the Sanitary Engineer’s per-item native trees for items 9/11/13/14/15; item 4 (cost-benefit, held under §9.66(D)) remains the one to watch.

Allen SWCD production (2026-06-12) — site stormwater; two “no records” tensions

Added 2026-06-12. A separate agency — Allen Soil & Water Conservation District — answered the relator’s own 11-item (Parts A–E) request about the 4110 N. Cole St. site’s stormwater/erosion jurisdiction. Ingested as prr-mandamus/bosc-prr-production-2026-06-12-aswcd.response-index.yaml (+ analysis); binaries (4-pp letter + 54-pp records bundle) under prr-production-2026-06-12-aswcd/. It produced the site ESC inspections (2025-12 → 2026-06), the County Engineer’s mass-grading approval + SW1225 stormwater permit ($5,800), and the plan-review email chain — and withheld the plan sets under a new dual ground (R.C. 149.433 infrastructure records + R.C. 1333.61 trade secret — “water and wastewater usage for a data center”), now withholding-map layer 7.

What’s owed / unresolved from this track:

Item(s)WhatSWCD posture
1The NPDES CGP coverage number for the siteSWCD didn’t produce it (“TBD” on every inspection form; pointed to Ohio EPA) — but acquired direct from Ohio EPA 2026-06-16: Turner’s coverage 2GC08468*AG, effective 2025-11-10 (permits/lma1a-npdes-cgp-coverage). The “TBD” was a SWCD recording gap, not absent coverage. Resolves #143.
3Wetland determinations (the 0.7-ac forested wetland, DSW401251760W)“No records”yet the produced inspections record “the existing wetland was mitigated.” A produced record contradicts the answer. (Corroborated by in-corpus permits/3788677 + /3796349.)
4Tile/agricultural-drainage impact”No records”yet the 2026-06-05 inspection documents an east farm-tile diversion swale failure (photo “East farm tile bypass”). A produced record contradicts the answer.
6–11BOSC-1A forcemain, Shawnee II Phase 2, Hume/Shawnee forcemain (MGD design capacity), MS Consultants comms, Commissioner Beth Seibert comms”No records” → deferred to Ohio EPA / Allen County Sanitary Engineer / townships.

The plan sets are the same documents the County withholds, now shielded a second way; the §149.433/trade-secret ground reaches even the plan-share links inside produced emails (redacted). Items 3 and 4 are the adequacy flags to carry forward.

The item-1 “TBD” feeds a permit-vs-disturbance ordering reconstruction — prr-mandamus/bosc-site-permit-sequence.yaml (+ narrative), #150: active clearing/mass-grading is documented from 2025-12-08 on a 195-ac footprint with the NPDES CGP number “TBD” through 2026-06-05, and the broader Level-2 wetland fill (DSW401252260W) was filed 2025-12-09 — the day after clearing — then found incomplete 2025-12-23. Both are framed as open questions; the dispositive CGP coverage record is pursued under #143.

NPDES coverage thread RESOLVED (2026-06-16). Three pieces were ingested 2026-06-16. (1) The governing statewide general permit OHC000006 (+ its Response to Comments) is committed at ../regulatory/ohc000006-construction-stormwater-gp.yaml — the standard is now primary-source: a complete NOI is due “at least 21 days … prior to the commencement of construction activity” and “Coverage under this permit is not effective until an approval letter … is received.” (2) The campus coverage record itself (../permits/lma1a-npdes-cgp-coverage.epa.yaml, Ohio EPA facility file): Turner’s 2GC08468*AG effective 2025-11-10 (NOI 2025-10-29), Igel added as co-permittee (*BG, 2025-11-12), modified to 309.2 ac 2026-06-10 — coverage attached ~4 weeks BEFORE the 2025-12-08 documented disturbance, so the SWCD’s “TBD” was a recording gap, not absent coverage (closes #143 + #154). (3) The BOSC Storm Outfall’s own coverage is end-to-end on the record too — eDoc 4091289, Facility Permit Number 2GC08747*AG (effective 2026-04-22; Igel/WSP). Note the per-site number format is 2GC…*AG, not an OHC… number (OHC000006 is the general permit).

Cross-production referral map (#151)

With three producing bodies now on the record — Commissioners (batch 1), Sanitary Engineer instruments (batch 2), and the ASWCD — the “no records” answers form a referral structure: each body disclaims a slice and points to the next. Mapped item-by-item (who disclaimed, who they pointed to, whether anyone produced it) in cross-production-referral-map.yaml.

Item(s)Disclaiming bodyPointed toProducer in corpus?
County 5–15CommissionersSanitary EngineerYes — produced in batch 2 (the referral that didn’t dead-end)
County 16 (CMS edit history)Commissionersthird-party web hostNo — records exist at the host (WordPress; REST API 401, not 404)
County 19 (EMH&T comms)CommissionersSanitary EngineerNo County↔EMH&T comms produced (ASWCD produced its own EMH&T emails)
ASWCD 6 (BOSC-1A forcemain NPDES/SWPPP/ESC)ASWCDOhio EPA / Sanitary EngNo — batch 2 gave procurement, not the environmental-stormwater records
ASWCD 8 (Shawnee II Ph2 stormwater/ESC)ASWCDOhio EPA / Sanitary EngNo — batch 2 gave the upgrade resolutions, not the ESC/NPDES records
ASWCD 9 (Hume/Shawnee forcemain MGD capacity)ASWCDOhio EPA / Sanitary EngNo — batch 2 gave financing + the engineering contract, not the MGD figure
ASWCD 7 (forcemain drainage/tile/wetland)ASWCDSanitary Eng / townshipsNo — townships not yet a requested custodian

Headline: the corridor-level environmental records (NPDES construction-stormwater / SWPPP / ESC for the forcemain corridors and Shawnee II Phase 2, plus the item-9 MGD design capacity) are owned by no county body — each points to Ohio EPA or the townships. The County’s Sanitary-Engineer batch produced the procurement / financing / resolution layer of those same projects but not their environmental-permit layer. A routing map, not an accusation — but it isolates exactly where the relator must go next (Ohio EPA; the townships) and which referral already resolved (Commissioners→Sanitary, items 5–15).

City of Lima track (#1536) — the un-requested municipal water & wastewater custodian

Added 2026-07-14. To date the campaign has served the County (Commissioners → Sanitary Engineer), the Allen SWCD, and Ohio EPA — but nothing has ever been requested from the City of Lima, the contract utility provider on both ends of the water balance the investigation turns on (supply: Auglaize/Ottawa → Lima WTP; wastewater: FM-2 → City of Lima WWTP). A first City-of-Lima R.C. 149.43 request is the standing worklist in #1536 — an external-dependency tracker, not yet served.

What was obtained from public sources without the request (2026-07-14). The one load-bearing City record that needed no PRR — the City of Lima WWTP’s own NPDES permit and design flow, which the corpus previously lacked entirely (greps returned American-Bath 2PH00007 / Shawnee II 2PK00002, never Lima’s plant) — was pulled straight from the public record:

  • The renewal permit — Ohio EPA NPDES 2PE00000*OD (application OH0026069), City of Lima WWTP, from the Ohio EPA DAM (public record). ../oepa/2PE00000.npdes.yaml (source 2PE00000.pdf). Establishes on a primary footing: outfall 2PE00000001Ottawa River at River Mile 37.6; 18.5 MGD average design flow (70 MGD peak wet-weather); final WQBELs (TSS/ammonia/TP/DO); a State-Approved Pretreatment Program (approved 1992; categorical users 0.71 MGD + significant non-categorical 0.412 MGD); and a renewed general mercury variance. Registered in the Lima SiteProfile.npdes_permits.
  • The reported effluent record (DMRs)../oepa/lima-wwtp-OH0026069.dmr.yaml, verbatim EPA ECHO effluent-chart data (2023-01..2026-06): actual mean 13.07 MGD (70.6% of design), 5 CSO/bypass outfalls, and 33 ECHO-flagged effluent exceedances (ammonia, E. coli, mercury, Ceriodaphnia toxicity, pH, TSS).
  • Water-balance effect. The 18.5 MGD municipal design flow is now counted in the routed mass balance (network.yaml lima-wwtp node), flipping the model’s previously self-documented conservative undercount: at design low flow the Ottawa leaving Lima computes 98% treated effluent (up from the 93% that county WWTPs + campus FM-2 alone produce). The ECHO POTW inventory’s null Lima-WWTP receiving water was corrected to the Ottawa River, permit-cited (data/reference/echo/maumee-wwtp.potw.yaml).

What still requires the request (owed / unrequested — #1536 Parts A–F). Everything below is City-held and not obtainable without the PRR:

PartWhatCustodian
AThe water-supply / bulk-water agreement (Bistrozzi/Tilted Gate/Google/BOSC), source-water capacity & drought-contingency studies, the $13.6M water-infrastructure cost allocation, the state water-withdrawal registrationUtilities Dept. / WTP; City Engineering
BThe FM-2 sewer/treatment agreement, WWTP capacity/headroom quantifying the campus’s allocated share, the campus Industrial User (IU) / significant-industrial-user pretreatment determination, SSO/I&I correspondenceWater Pollution Control / WWTP; Pretreatment coordinator
CCity CRA / TIF / enterprise-zone / CEDA instruments, the City’s cost-benefit / public-ROI analysis, City↔AEDG comms, any NDACommunity/Economic Development; Law Director
DCouncil ordinances/resolutions (water/sewer service, the infrastructure spend, easements), any annexation / JEDD touching 4110 N. Cole St.Clerk of Council
EPlans/permits/easements for the City-side water mains and the FM-2 forcemain; EMH&T correspondenceCity Engineer
FFire pre-incident / hazmat plan for the 113 fuel-storage tanks + gensets (may belong to the township FD if outside the City fire district)Lima Fire Division / township FD

SERVED — and answered in part (2026-08-22 / 2026-08-24). The request in the table above is no longer an external-dependency tracker: it was served on Director Caprella and drew two rolling partial responses two days apart, 22 files. Four of eleven items produced responsive records; seven drew nothing, with no cover letter, no itemised response, no privilege log, no exemption claim and no statement that any record does not exist. Mapped item by item in prr-mandamus/bosc-prr-production-2026-08-lima.response-index.yaml (analysis: …analysis.md; custody: …custody-manifest.yaml).

What landed, against the Parts A–F table above:

  • Part A (partial) — the 2022 NPDES renewal application (EPA Forms 1/2A/2S + antidegradation addendum). New to the corpus: a collection-system inventory of 20 CSO outfalls and 34 constructed sanitary-relief points with coordinates, 17 of which discharge to Pike Run — the campus storm outfall’s receiving water. It also corrects a corpus reading: the permit’s “CSOs reduced to five events per year” is an event cap, never an outfall count. The application’s own named attachments (storm drainage plan, process flow diagram, plant map) were not produced, and neither was any City↔Ohio EPA correspondence file (item A.2).
  • Part B (substantially produced) — six weekly ammonia benchsheets, the corpus’s first primary lab record for any facility, plus the City’s two 2026 noncompliance notifications. February’s reported monthly average and worst-week maximum both recompute from the City’s own duplicate analyses to four significant figures against EPA ECHO. January does not reconcile: the 2026-01-29 result is blank on the produced benchsheet and the weeks of 01/04 and 01/11 were not produced. March forward, any corrected DMR, and the City’s own NOV response are all missing.
  • Part C (split) — the ten sanitary-capacity acceptance letters (item 5) arrived; the capacity/headroom analysis (item 4) and every data-center service record (item 6) did not. No produced record names 4110 N. Cole Street, Bistrozzi LLC, Google, Project BOSC, a data center or a large water-cooling user. ⚠️ That is a negative result about the production, not about the world — the City asserted no exemption and made no no-records statement.
  • Parts D and E (nothing) — no SIU/CIU inventory, no IU permits or applications, no pretreatment annual reports for 2023–2025, no CSO long-term control plan, no annual CSO reports.
  • Part F (partial) — the City↔County biosolids agreement (executed 2023-12-05) covering all three County plants including American Bath, the plant the County’s 2.5 MGD BOSC forcemain feeds. None of the correspondence, negotiation records or engineering submittals the item also asked for; nothing naming OSU or Dr. Shedekar; nothing on the BOSC pump station and forcemain.

The gap has a shape worth stating: every item the City answered concerns a record Ohio EPA also holds, or a routine instrument the City issues to third parties. Every item requiring the City to characterise its own capacity, its own industrial users, or its own dealings about the campus drew nothing. That is a distribution, not a finding of intent — and it is testable by re-serving those seven items so a non-response must become either a production or a stated exemption.

The permit + DMR ingest resolves the B2 permit/design-flow component and partially answers the item-9 municipal-design-capacity gap the referral map leaves owned by no county body; the frontend dilution-feed / scenario snapshot still reflects the pre-#1536 county+campus subset (93%) pending a separate bundle regen. Frame against the §9.66(D) reflex (see ../../../docs/legal/mandamus-analysis.md §II): the utility/public-works/environmental records above are a far weaker §9.66(D) fit than incentive terms, and records predating its 2026-03-20 effective date are presumptively still public.


2. Watershed / conservation grant docs — to dig up

A captured Allen SWCD project page entered the corpus 2026-06-06 as watershed/osu-lima-ag-runoff.allenswcd.2026-06-06.pdf (extraction: watershed/osu-lima-ag-runoff-treatment.capture.yaml). It documents a $650,000 ag-runoff retention/treatment grant (Project ALLENSWCD-FDFARM22) on Lost Creek HUC12 041000070305 — a Maumee headwater 2.7 mi east of I-75 — i.e. baseline nutrient-burden context for the hydrology axis. The page is a secondary SWCD summary.

The project’s Lead PI, Dr. Vinayak S. Shedekar (OSU FABE), was identified from the page; his CV (shedekar-cv.2025-09-28.pdf, provided 2026-06-06; bibliography at ../watershed/shedekar-vinayak.bibliography.md) resolved the funding source: Great Lakes Restoration Initiative (GLRI), subaward through Ohio EPA, OSU portion $327,450, term 2023–2025 (CV grant #13) — closing the prior [open]. The primary instruments still owed:

ItemWhat’s owedWhere to get it
Grant agreement / award instrumentThe signed GLRI / Ohio EPA subaward itself — deliverables, match, reporting (program now known; instrument not in hand)Ohio EPA GLRI subaward files; Allen SWCD; public-records request
OSU application & conceptual designEngineering basis for the BMPs (berm/wetland/forebay/pump-vault; saturated buffer)OSU FABE (Dr. V. Shedekar); Allen SWCD project file
Load-reduction estimate tableReferenced on the captured page (“provided in the table below”) but not transcribed in the captureRe-capture full page / SWCD project file
OSU monitoring dataContinuous flow + water-quality (3 sites, ISCO6712 samplers) — quantifies actual nutrient/flow reductionOSU Overholt Drainage program

These quantify the existing Maumee-headwater load and remediation spend the corpus reasons against; the funding source is now verified, the rest not yet in hand. Cross-ref the ECHO Maumee discharger inventory (../../reference/echo/) and ../../../docs/HYDROLOGY.md.


3. Corpus-integrity gaps (minor)

Commissioners minutes series — broadly complete

934 files in commissioners/minutes/raw/ spanning 2023–2026: 475 agendas (A…) / 453 minutes (M…), 468 distinct meeting-dates parsed. The 22-file agenda/minutes asymmetry is mostly not real absence:

  • Recent publication lag (not a gap): 12 dates 2026-03-03 → 2026-04-20 have an agenda but no minutes — these are the most recent meetings relative to the 2026-04-17 manifest snapshot; minutes simply weren’t posted yet.
  • Partial 2023 backfill (scope, not loss): an 8-date cluster in Dec 2023 (agendas, no minutes) sits in the partially-backfilled 2023 range (the corpus is pinned to 2024–2026).
  • Typo’d agendas masquerading as gaps: several early-2024 “minutes, no agenda” dates do have an agenda under a malformed name — e.g. A20524-Special.pdf (2024-02-05), A22124-Special-1.pdf (2024-02-21), A22824-Special.pdf (2024-02-28).

~12 malformed / misfiled filenames (break automated indexing)

FilenameIssue
Govt.-Structure-Org-Chart-1.pdfNot a meeting record — reference handout misfiled in minutes/raw/
Mayors-and-Zoning-Persons.pdfNot a meeting record — contact list misfiled
Township-Trustees-Fiscal-Officers.pdfNot a meeting record — contact list misfiled
CANCELLED-MEETING.pdfCancelled-meeting placeholder (no date)
Board-of-Commissioners-General-Session-September-9-2025-Meeting-Minutes.pdfLong-form name for the 2025-09-09 minutes (should be M090925.pdf)
ACC-M102423.pdfStray ACC- prefix (minutes 2023-10-24)
A0101024.pdf, A0404024.pdf, M0115226.pdf7-digit date typos — ambiguous; verify against the source before renaming
A20524-Special.pdf, A22124-Special-1.pdf, A22824-Special.pdf5-digit dates (leading zero dropped)

PRR-01 bundle derived files — not committed (low concern)

The bundle index references seven derived_files (Allen_County_PRR_searchable.pdf, ..._full_text.txt, ..._exhibit_index.txt, Allen_County_Project_Master_Table.md, WATERMARK_Tetra_Tech_OPC.yaml, WATERMARK_OPC_Detailed_Line_Items.yaml). None are in data/documents/aedg/ — but they are regenerable derivatives of PRR-01-bundle.ocr.pdf, which is present. Not lost source material.

Sanitary as-built present but not yet extracted

Added 2026-06-11 (issue #41). sanitary/indianbrook-ps-asbuilt-2007.pdf — the 2007 Indian Brook pump-station as-built (4-page scan, no text layer) — is present in the corpus but not yet grounded: data/extracted/sanitary/ carries no structured extraction, so the 8” forcemain / three-phase upgrade it documents is cited only secondhand (data/reference/periplus/watch-items.geojson “2007 as-built”; ../../../docs/legal/mandamus-analysis.md §503). The discipline-agnostic kind=engineering / kind=sanitary extractor (watermark.pipeline.extract.extract_engineering) now exists; the structured .sanitary.yaml awaits a keyed vision pass (ANTHROPIC_API_KEY, tracked in #124). This is the one piece of sanitary as-built evidence that is in hand against the Category-B wastewater hole above (§1, items 5–15).

Provenance — clean

Every *.pdf cited across extracted/** resolves to a real file under data/documents/. (Of 94 distinct cited names, the only 2 “unresolved” are false positives: a Google-Slides export title and a prose fragment, not file references.) The 5 PRR-production binaries named in the response index are all present in prr-production-2026-06-05/ — the index’s “binaries to be added” note is stale.


4. Air permit (PTI P0138965) — keystone power figure — INGESTED 2026-06-15

Added 2026-06-09 (compute-capacity axis); resolved 2026-06-15. The Ohio EPA Air Permit-to-Install P0138965 (Facility 0302022054) is the keystone behind the campus’s disclosed electrical scale — 114 emergency generators × 2,750 ekW ≈ 313 MW backup → ~250–300 MW IT (N+1) — anchoring both the cooling-water balance (../../../docs/HYDROLOGY.md; watermark.hydrology.cooling) and the compute / AI-capacity derivation (../../../docs/COMPUTE.md; watermark.facility).

Now ingested. The 2026-05-28 final PTI (Ohio EPA eDocument 4132514, 66 pp incl. a 64-item Response to Comments) is committed at ../../documents/permits/bistrozzi-permits/4132514.pdf../permits/4132514.epa.yaml. It joins the already-committed 2025-12-10 draft of the same permit (3987141 / 3987144) — which it supersedes and whose flagged 114-vs-115 generator discrepancy it resolves.

What it puts on a primary footing:

  • Genset count + the three-hall grouping. 115 emissions units P001–P115 — P001–P114 are identical data-hall gensets in three groups of 38 (GEN 1/2/3), P115 is a separate, smaller HUBGEN; the 36 cooling towers are three groups of 12 (TWR 1/2/3). The three-group emission-unit structure corroborates the anticipated ≈ three data halls (38 gensets + 12 towers each).
  • Synthetic-minor caps: NOx 235.62 tpy + CO 96.06 tpy (rolling 12-month, P001–P115 combined) — the federally enforceable limits keeping the facility under major-source NSR (it is major for Title V); Tier 2 CI engines under 40 CFR 60 Subpart IIII, fueled ULSD/HVO ≤ 15 ppm S.

What it does NOT resolve (carry forward):

Still owedWhyWhere to get it
Per-engine ekW / engine make-modelCBI-LOCKED, confirmed 2026-06-16 (#159)The DAPC application file was acquired: Ohio EPA granted trade-secret protection for the “size/rating of emergency generators and fire pumps” (OAC 3745-49-03, grant 2025-10-08; permits/3859883 + justification 3859888). The exact ekW lives only in the confidential version of A0080278; the 2,750 ekW × 114 ≈ 313 MW basis stays the draft public-notice figure and is not obtainable absent a legal challenge to the designation. Surviving public brackets: main gensets ≥ 560 kW (Tier 2).Closed — only a trade-secret challenge would unlock it
Emission-unit plot plan / building footprint — also trade-secret-shielded (#160)The same trade-secret grant covers “internal layout details” — so the footprint is shielded at the DAPC level too (atop the County/ASWCD R.C. 149.433 + 1333.61 withholding). Method 3 stays the land-area envelope.Township building-permit filings; a trade-secret/PRR challenge
Architectural site-plan sheets (CI Design / WSP)The committed plan set is a single grading & storm sheet (1A-C-3104) showing only ancillary SSS/GPS buildings on piers — the data-hall footprints sit on architectural sheets not in hand (see #160).EMH&T / CI Design plan set; PRR follow-up

Net: the genset count, three-hall emission-unit grouping, and synthetic-minor caps are primary-source; the 313 MW per-unit ekW is now confirmed trade-secret-locked (#159 closed — the application file withholds it under an Ohio EPA OAC 3745-49-03 grant), so it permanently rests on the draft public notice absent a legal challenge; and Method 3 stays the land-area envelope — the floor area / internal layout is itself trade-secret-claimed (#160).


5. Grid / transmission — AEP Ohio “Lyka” 345kV substation + line — INGESTED 2026-07-11

Added 2026-07-11 (issue #1476, surfaced by the exploratory web-research refresh). Until now the corpus’s power story ran only through the OEPA air-permit generator count (§4) — the permit’s own Response to Comments explicitly punted grid/interconnection questions to PUCO/the utility (“Power Grid (referred to PUCO / utility)”). AEP Ohio’s Lyka Transmission Project — a new 345kV substation on a customer-owned parcel between N West St and N Cole St, plus ~4 miles of new 345kV transmission line, both in Sugar Creek Township — is the first primary-utility-project instrument that begins to answer that referral.

Now ingested. AEP’s own project fact sheet and study-area map (captured 2026-07-11, dated 2026-04-08) are committed at ../../documents/grid/aep-lyka-2026/../grid/aep-lyka-transmission-2026.project.yaml.

What it puts on a primary footing:

  • Project scope + schedule. Substation site, ~4mi 345kV line, steel monopole structures (140-170 ft, ~150 ft ROW), and a dated schedule: OPSB regulatory filing “Early 2027,” anticipated OPSB decision “Spring 2027,” construction Fall 2027 - Summer 2028, in-service Summer 2028.
  • No OPSB case filed yet. Direct search of opsb.ohio.gov and AEP’s own regulatory-filings index turned up no case number as of 2026-07-11 — consistent with AEP’s own “Early 2027” filing target. A distinct Ohio History Connection/SHPO submission (OHPO project ID 2026ALL68059, “Lyka Station STATCOM Project,” received 2026-04-08) is a separate historic-preservation review track, not the OPSB siting case.
  • Open-house date reconciled. No real conflict: the 04-21-dated LimaOhio.com/Bluffton Icon coverage announced the 05-06 open house two weeks out; a follow-up LimaOhio.com piece (published 05-07) confirms the event itself was held Wednesday 2026-05-06 — matching AEP’s own fact sheet.

What it does NOT resolve (carry forward):

Still owedWhyWhere to get it
Named customer/loadNeither AEP’s project page nor its fact sheet names a customer (“a commercial customer’s facility”); AEP outreach staff told press they can’t disclose customers.An OPSB application (planned Early 2027) will require the load/customer to be identified.
Final transmission-line routeAEP’s own map shows 45 numbered candidate “study segments”; the company selects one route only after public input + feasibility review — none is fixed yet.The OPSB application/certificate, once filed.
Google/Bistrozzi attributionLocal press (LimaOhio.com, 2026-04-21: “AEP Ohio plans substation on Google property… on Google’s under-construction property”) ties the substation to the Bosc campus, but this is secondary reporting only — no primary AEP/OPSB document corroborates it. Stays [inference].The OPSB filing (once it names the load), or a direct AEP/Google statement.

Net: the project’s scope and schedule are primary-source (AEP’s own fact sheet); the absence of an OPSB filing is a direct-search finding (opsb.ohio.gov + AEP’s regulatory-filings index, as of 2026-07-11), consistent with that schedule’s Early-2027 target; the customer identity and final route are not yet established and are tracked [open]/[inference] accordingly. A standing lead (data/site/leads.yaml id AEP-LYKA-OPSB) tracks the filing for when it lands.


Genuine-absence shortlist — VERIFIED 2026-06-12 (#46)

All 8 low-confidence dates were checked against commissioners.allencountyohio.com (year-specific minutes + agenda archives, raw-link inspection). None is a corpus capture lag — our holdings already mirror what the county publishes. Outcomes are recorded per-date in ../commissioners/minutes/filename-map.yaml under genuine_absence_verified:. Summary:

  • Minutes present, no agenda → special-session structure (no separate agenda is ever published): 2023-03-22, 2023-06-21, 2025-08-13, 2025-11-14 — all confirmed “-Special Session” upstream. (Correction: 2024-06-20, also on the old shortlist, is not special — the held M062024.pdf is a regular Thursday session; its agenda is genuinely absent upstream, the county never posted an A062024.)
  • Agenda present, minutes never captured → genuine upstream absence (county never posted minutes): 2024-09-25 (Wed between regular Tue/Thu sessions), 2024-12-30 (year-end special session), 2025-12-30 (the county page’s “December 30, 2025” minutes link is mislabeled — its href points to the Dec 23 file M122325.pdf; no real M123025.pdf exists upstream).

No corpus action required for any of the 8.

Full civic cutover (2026-06-12, #133 follow-on): the commissioners’ entire meeting record (Jan 2023–, 991 files) is now connector-sourced under data/documents/commissioners/meetings/. The legacy hand-assembled minutes/raw/ tree (930 PDFs) was retired after every file was verified byte-identical to its connector copy — the per-file record is cutover-reconciliation.yaml (930/930 matched, 0 retained). The download manifest + meeting index sit alongside it. OCR pass complete (2026-06-12, #135): all 991 files text-extracted, 969/991 dates content-verified and 270 meetings flagged for corridor topics (up from 497/91 when only the agendas had a text layer). The “934 files in minutes/raw/” figures above describe the pre-cutover 2026-04-17 snapshot.


Cross-refs