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Project BOSC — Research Dossier (v1)

What this is. A synthesis of everything BOSC has deconstructed from the public-records corpus into structured data, assembled across documents via the cross-document layer (watermark.pipeline.corpus → entities + timeline). It is generated from, and cites, the committed artifacts under data/extracted/**.

Evidence discipline. Claims are tagged [verified] (read from a committed extraction, cited) or [inference] (a reading of the assembled record, labelled as such). This is a synthesis of public records — registered-agent and organizer overlaps are common-control plumbing, not statements about beneficial ownership, and shell-adjacent signals are evidence, not verdicts.

Corpus as of this writing: 48 extracted documents — 5 deeds, 9 NPDES, 3 SoS filings, 30 Ohio EPA/USACE permit actions, 1 site plan, 1 OPC roadwork summary → 36 resolved entities, 39 relationships, 44 dated events.

1. Executive summary

What it is. A large, hardened data-center campus — the “American Industrial Park Site” on the North Cole Street corridor in Allen County (Lima), Ohio — built by a Delaware shell entity, Bistrozzi LLC, which assembled the land, is driving the environmental and infrastructure permitting, and is the named beneficiary of a privately-funded $14.2M public roadwork program routed through the Allen County Port Authority. County-operated wastewater capacity on the same corridor (three WWTPs) forms the utility backdrop.

Who it is for — Google. The end user is Google. The Port Authority’s own (PAAC) board minutes record it, and the Lima-Allen County Regional Planning Commission minutes independently name the project “project BOSC (Google data center)” — alongside $250,000/yr to Elida Schools and $1.5 billion invested if all three phases proceed. [verified: data/extracted/aedg/paac-board-minutes.minutes.yaml + data/extracted/lacrpc/meetings/meeting-summaries.yaml] That attribution is corroborated by the sibling shell thread: Tilted Gate LLC — same registered agent, same organizer as the Bistrozzi cluster — filed its parallel “Project Dazzler” with an applicant contact signing as randybarrera@google.com (§8). And the AEDG release is now in the corpus: AEDG “is thrilled to reveal Google as the business entity behind Project Bosc” (2026-03-16), with a named Google official (Molly Kocour Boyle, Head of Midwest Data Center Public Affairs). [verified: data/extracted/aedg/aedg-data-center-release.release.yaml] So the “who” is settled on three independent corpus sources (AEDG release, PAAC minutes, LACRPC minutes); what remains open is beneficial ownership of the shells (§11), not the customer.

The data-center identity is likewise not inferred from massing alone: an Ohio EPA air permit names “Bistrozzi LLC Data Center – Initial Installation” and the site plan shows a substation, anti-ram barriers, security fencing, and containment areas. [verified: data/extracted/permits/3987141.epa.yaml, data/extracted/plans/LMA1A-95-SPS-2025-10-28.plan.yaml]

What this dossier is for. With the who and the what settled, this is the analytical background for the questions that remain: the timeline opacity (how the record was kept thin, and what that conceals about sequence and intent), the use cases and compute capacity the plans imply, the public cost against public benefit, and the forecast of what this campus does to the corridor’s water, air, and tax base. The opacity is itself one of the findings — the public record is designed to be thin: ORC §9.66(D) (Sub. H.B. 184, eff. 2026-03-20) categorically excludes economic-development project information from disclosure, layered atop NDA-by-default, a Delaware-shell counterparty, and permitting segmented across agencies. The structured corpus below is the reconstruction — each fact reassembled from a primary permit, deed, or filing that segmentation could not suppress. [verified: statute] / [inference: framing]

2. The entity at the center — Bistrozzi LLC

BISTROZZI LLC is the hub of the graph: grantee on 4 deeds (11 parcels), applicant on ~20 EPA permit actions, a Delaware foreign LLC. [verified: entity graph; signals=['delaware']]

2.1 The Delaware shell cluster

Three sibling LLCs file as Delaware foreign LLCs through overlapping fingerprints [verified: data/extracted/permits/sos-*.sos.yaml]:

Magenta Capital and Tilted Gate share both registered agent (CSC) and organizer (Montfort); Bistrozzi LLC and Tilted Gate also share a Wilmington, DE mailing address (2801 Centerville Rd — a private-mailbox/agent address). [verified: data/extracted/permits/3796349.epa.yaml, data/extracted/permits/4081910.epa.yaml] These are common-control signals across the cluster, not beneficial-ownership findings. [inference]

3. Land assembly — the corridor block

Five conveyances, all recorded to Bistrozzi LLC, assemble a contiguous block. [verified: data/extracted/recorder/*.deed.yaml]

Cross-check: BOSC’s deed extractor independently reproduced Periplus’s frozen hand-curated parcel ledger 11/11 (tests/test_periplus_crosscheck.py). [verified]

4. The data center — site plan & air permits

Site plan LMA1A-95-SPS (95% Site Plan Set, Grading & Storm, 1”=30’, 2025-10-28): project “American Industrial Park Site,” Lima, OH 45801, designed by EMH&T (Civil), CI Design Inc (Architecture, Boston), WSP USA Buildings (MEP/Structure, Troy NY). Legend features include a substation, transformer, anti-ram barriers, permanent + temporary security fence, fiber duct bank, containment areas, and “SSS/GPS buildings on piers.” [verified: data/extracted/plans/LMA1A-95-SPS-2025-10-28.plan.yaml]

Air permitting confirms scale: Ohio EPA Air Pollution Permit-to-Install P0138965 for the “Bistrozzi LLC Data Center – Initial Installation” — the public notice references ~114–115 backup generators (~2,750 ekW). [verified: data/extracted/permits/3987141.epa.yaml, data/extracted/permits/3866942.epa.yaml]

Zoning jurisdiction. A parcel-by-parcel join against the City of Lima zoning layer returns 0 of 48 cited corpus parcels inside city limits: the corridor sits in American/county townships, so the project is not subject to the City of Lima zoning code. Allen County GIS publishes no county/township zoning layer (only Tax and School districts), so the controlling land-use authority is township/county — not the city, and not GIS-mapped. [verified: data/reference/lima-gis/parcels.zoning.yaml]

5. Water — wetlands, sanitary sewer, county WWTPs

Wetland / 401 permitting (Project Bosc): a sustained Ohio EPA Division of Surface Water thread runs 2025-07 → 2026-02 — a Level-1 Isolated Wetland Permit (DSW401251760W: application → incomplete → approved), a mitigation-bank credit purchase, then a Level-2 IWP (DSW401252260W: application → incomplete → comments). [verified: data/extracted/permits/*.epa.yaml]

Sanitary sewer: Surface Water Permit-to-Install DSWPTI-260294, “BOSC-1A Private Sanitary Sewer Improvement Plan,” 4110 N Cole St — application 2026-03-17, approved 2026-04-07 (Turner Construction is GC). [verified: data/extracted/permits/4074527.epa.yaml, data/extracted/permits/4074551.epa.yaml]

County WWTP capacity (utility backdrop): three Allen County plants on the corridor [verified: data/extracted/oepa/*.npdes.yaml]:

Note the resonance: Pike Run Farms LLC (a Bistrozzi grantor) shares its name with Pike Run, the American Bath WWTP’s receiving water. [verified]

Downstream — the Maumee Nutrient TMDL. All three plants discharge (Ottawa → Auglaize → Maumee) into Lake Erie’s largest tributary, under the US-EPA-approved 2023 Maumee Watershed Nutrient TMDL, which assigns each an individual total-phosphorus wasteload allocation (spring-season metric tons: Shawnee No 2 0.75, American-Bath 0.37, American No 2 0.30; the main Lima WWTP 4.0). So the same effluent the low-flow screen shows is effectively undiluted is also capped at the basin scale by a binding nutrient budget — local dilution failure on top of a Lake-Erie phosphorus cap. [verified: data/reference/hydrology/maumee-tmdl-wla.yaml]

Atmospheric water budget (NASA POWER + FAO-56). The corridor’s climate normal is ~997 mm/yr precipitation against ~1,085 mm/yr of reference ET0 (FAO-56 Penman-Monteith from the NASA POWER normals) — a −88 mm/yr net, with ET0 exceeding rainfall every month May–Oct. The growing-season water deficit lands in exactly the months the Ottawa is at its low-flow floor, so peak evaporative demand and any consumptive cooling draw coincide with minimum river supply (see the hydrology report §3–4). [derived: FAO-56 Penman-Monteith over data/reference/hydrology/nasa-power-climatology.yaml]

The seasonal pinch, quantified. Screening the sourced data-center cooling draw (~4.85 cfs net consumptive, central estimate) against the Ottawa’s cited seasonal low flow — not just the annual 7Q10 — sharpens the conclusion. Across the May–Oct growing season (exactly the months reference ET exceeds precipitation), the draw is ~3× the cited summer 30Q10 (1.6 cfs); the annual-7Q10 figure (~24×, 0.2 cfs) understates the in-season constraint by reading against a floor that does not apply in summer. And 30Q10 is the generous seasonal floor — the Ottawa’s absolute design low flow is 1Q10 = 0 cfs, so in the driest growing-season weeks there is no flow to draw against at all. The cooling draw peaks against supply precisely when the atmosphere is also taking the most. [derived: cooling basis vs cited 30Q10/7Q10/1Q10, data/reference/hydrology/low-flow-7q10.yaml]

Floodplain. The recorded campus parcels sit just outside the FEMA Special Flood Hazard Area, but Zone AE (1%-annual-chance) floodplain and regulatory floodway (FEMA DFIRM 39003C) come within ~50 m of the footprint — a no-rise corridor the post-development stormwater increase drains toward (see hydrology). [verified: data/reference/hydrology/campus-floodzone.yaml]

Toxic-release baseline (EPA RSEI). The corridor sits in a long-industrial county. EPA’s Risk-Screening Environmental Indicators set ranks 49 Allen County TRI facilities by modeled, population-weighted Score; the top emitters are INEOS Nitriles, the WHEMCO-Ohio foundry, and Lima Refining — and, notably for the defense thread, the JSMC / General Dynamics Land Systems plant at #4 (~3.05 M Score, 98% cancer-weighted, chiefly nickel compounds, reported 1988–1993). That is an independent federal dataset naming GDLS at the JSMC, corroborating the defense-contractor scan’s reading of the Army-owned footprint — and the GLEIF registry independently records that General Dynamics Land Systems Inc. (LEI 875500ULXB4CYQSJVA03) reports its ultimate parent as General Dynamics Corporation, confirming the ownership chain [verified: data/reference/gleif/lei-records.yaml]. The per-facility water release bucket ties into the dilution analysis above and the Maumee NPDES inventory via ECHO coordinate matches (RSEI v2.3.12 no longer carries a facility NPDES permit). [verified: data/reference/rsei/inventory.yaml]

Toxic load meets the lowest dilution (RSEI × 7Q10). Extending the low-flow assimilative screen from the three municipal WWTPs to the industrial dischargers exposes a sharper coincidence: of the 13 county facilities that release toxics to water, the three largest — INEOS Nitriles, Lima Refining, and PCS Nitrogen — all cluster on the Ottawa River at Lima, whose cited design low flow is 0.2 cfs (1Q10 = 0). Their reported water releases screen at roughly 51 / 131 / 263 mg/L if carried at that 7Q10 — i.e. the county’s heaviest toxic loads enter the one reach with essentially no assimilative capacity, and that floor falls in the same May–Oct window the atmospheric budget runs to deficit. Only Lima Refining’s receiving water is independently ECHO-cited (OH0002623 → Ottawa River); INEOS and PCS are corridor inferences, flagged as such. The mg/L figures are a coarse [inference: derived] order-of-magnitude screen, not measured concentrations. [verified: data/reference/rsei/toxic-discharge-screen.yaml]

Who owns the dischargers, and who benefits from federal dollars. Two ownership layers now sit on the entity graph. First, an industrial-ownership layer folds each Allen County RSEI facility into its GLEIF-resolved corporate parent (owned_by): the Ottawa-corridor toxic dischargers map to INEOS USA LLC, Cenovus (via Husky, the Lima Refining parent), and Shell (Equilon), alongside Ford, Marathon, Dana, Textron, and P&G — so the toxics screen above resolves to named, LEI-pinned owners. [verified: data/reference/gleif/lei-records.yaml + data/reference/rsei/inventory.yaml] Second, a federal-award layer stamps USASpending all-time prime-award obligations onto the verified corridor parties: the corridor’s federal defense nexus — General Dynamics Land Systems (the JSMC operator, ~$33.6 B) and its parent General Dynamics Corp (~$299 B, which USASpending independently records as GDLS’s parent, corroborating the GLEIF chain). The data-center end user is Google (the PAAC/LACRPC minutes, §1, §6); the sibling Tilted Gate / Project Dazzler filing carries the google.com applicant email (§8). Google is deliberately kept off the entity graph as a node — not because the customer is unknown, but to hold the graph to corpus-verified edges and keep its federal-award figures (Google LLC ~$73.5 M) from being read as a Lima-campus obligation. The attribution lives in the prose and the candidates layer, not as a fabricated graph party. [verified: data/reference/usaspending/awards.yaml]

6. The public ledger — what the abatement costs vs. what it returns

The data center runs on a 15-year, 75% real-property tax abatement (Allen County CRA No. 1, Res #548-25 of 2025-07-10; CRA designation #003-99003-396), granted to Bistrozzi LLC — a Delaware shell c/o Vorys (Scott Ziance) — whose CRA §13(A) assurance is that its parent is a publicly-traded Fortune 100 company. [verified: data/extracted/legal/prr-mandamus/cra-agreement.cra.yaml] The statutory school-district notices were drafted and served not by the County clerk but by the Allen Economic Development Group (AEDG) — Cynthia Leis, President/CEO — the entity coordinating the abatement; both superintendents (Elida’s Joel Mengerink, Apollo JVSD’s Keith Horner) acknowledged receipt on 2025-06-25. [verified: data/extracted/legal/prr-mandamus/school-district-notice-letters.notice.yaml] Leis also serves as Executive Director of the Port Authority (which has no employees and signed the $14.5M roadwork deal) — one person directing both the econ-dev nonprofit and the public body — and the PAAC’s own minutes confirm the end user is Google. [verified: data/extracted/aedg/paac-records-policy.policy.yaml + paac-board-minutes.minutes.yaml]

What the public gives. 75% of the property tax on the ~$500M improvement, 15 years per building — a screening ~$84–129M in abated property tax, i.e. roughly $1.7–2.6M of abatement per promised job (the CRA estimates ~50 permanent jobs, ~$4M annual payroll, from a current zero). The dollar range is a stated assumption (Ohio commercial effective-rate band on the 35% assessed value), not a cited Allen County millage [inference: assumption] — yet even so it screens worse than the relator’s own Ohio comparable of ~$1M/job of revenue loss. Regenerate with watermark ledger.

What the public bears alongside (already quantified by the other threads):

• Toxics: 3 of 12 county toxic water dischargers sit on the Ottawa at Lima, the reach with ~zero assimilative capacity (7Q10 0.2 cfs, 1Q10 0).
• Water: a ~4.85 cfs consumptive cooling draw — 3× the Ottawa’s summer 30Q10, 24× the annual 7Q10, arriving in the May–Oct ET-deficit window.
• Roadwork drainage: $1.07M of roundabout drainage budgeted with only 1 of 6 estimates itemized and no detention sized.
• Federal nexus: the corridor’s defense anchor (JSMC operator GDLS, ~$34B all-time federal awards; parent GD Corp ~$299B).
• Air: 114 diesel emergency gensets (~313 MW backup), permitted synthetic-minor to stay just under major-source NSR review.
• Roadwork: a parallel $14.5M Roadwork Development Agreement (PAAC/Bistrozzi) builds 4 roundabouts + 2 road rehabs the County then maintains in perpetuity; RDA §5.5 lets State 629 / ODOD grants refund the developer’s “contribution” — so public money may fund the private share, while the actual award (Eagle Bridge ~$3.52M) runs far under the $14.5M collected. [verified: data/extracted/aedg/roadwork-development-agreement.rda.yaml + paac-board-minutes.minutes.yaml]
• Wastewater × TMDL: a new data-center sanitary load enters a fully-allocated, reduction-bound Maumee watershed (point-source future-growth reserve only ~1.4–1.5 mt P/spring basin-wide) and, as a new/expanding discharger, must add secondary + tertiary treatment to hit a 0.5 mg/L TP limit — a ratepayer cost the package omits. [verified: data/reference/hydrology/maumee-tmdl-budget.yaml + maumee-tmdl-responsiveness.yaml]
• Land conversion (CAUV): the assembled campus parcels were CAUV farmland; conversion triggers a one-time CAUV recoupment and pulls productive ag land from the Elida-LSD tax base — onto which the 75% abatement is then layered. [verified: data/extracted/aedg/seller-land-packets.land.yaml]

What the public can’t see — by the County’s own choices. The figures that would actually answer “is this a good deal?” are withheld: the County’s cost-benefit analysis (PRR request item 4, withheld under R.C. 149.43 / 9.66 as “being reviewed by legal counsel”); the School District Compensation Agreement dollar amounts (non-public, only the 25% floor disclosed — though the PAAC minutes surface a proposed $200K→$250K/yr PILOT to Elida, so the deciding figure demonstrably exists, and the Lima-Allen County Regional Planning Commission’s own minutes independently restate it: a DCC presentation on the project — named in the minutes as “project BOSC (Google data center)” — recorded $250,000 to Elida Schools and $1.5 billion invested if all three phases proceed); and the land-assembly purchase prices — the recorded deeds state only “valuable consideration” and the DTE-100 transfer-tax forms were produced with the price fields blank, so what was paid to assemble the ~350-acre campus is opaque (only the Neighbors parcel, $600K / 5.0 ac, is disclosed). And CRA §22 indemnifies the County’s attorney fees for defending exactly that kind of withholding — a private subsidy for public secrecy. [verified: cra-agreement.cra.yaml + seller-land-packets.land.yaml + paac-board-minutes.minutes.yaml + bosc-prr-production-2026-06-05.response-index.yaml + lacrpc/meetings/meeting-summaries.yaml]

7. Roadwork — privately-funded public infrastructure

Six Tetra Tech Opinions of Probable Cost (~$14.2M) cover roundabouts and corridor work at Cole/Diller, Cole/Bluelick, the Primary Access Entrance (Beery & N. Cole), and Cole/West (SR 115). The OPC states the program is privately funded via a “BOSC Team” deposit to the Port Authority (PAAC), to be dedicated to the County on completion — i.e. a private developer financing public road capacity through the port authority. [verified: data/extracted/aedg/roundabouts.summary.opc.yaml]

The executed agreement. The Roadwork Development Agreement (PAAC / Allen County / Bistrozzi, effective 2025-09-15; PAAC Res O.729-25, County Res 588-25) sets the deposit at a $14,500,000 “Company’s Contribution” (basis = the Tetra Tech OPC, per Exhibit D), builds the 4 roundabouts + Cole/Bluelick rehabs, and dedicates them to the County for perpetual maintenance. Three clauses matter: §5.5 refunds any “overpayment” — including State 629 / ODOD grant funds — back to the company, so public grants can backfill the private contribution; §9.17 exempts the company from any competitive procurement; and §9.13 is a third records-withholding lever (after the NDA §6 and CRA §22), binding PAAC to ≥5 business days’ notice to the developer before answering any records request and to redact all it lawfully can. The first real construction award — Eagle Bridge, ~$3.52M (2026-04-23 PAAC minutes) — runs far below the $14.5M collected, sharpening the §5.5 refund question. [verified: data/extracted/aedg/roadwork-development-agreement.rda.yaml + paac-board-minutes.minutes.yaml]

Drainage scope vs the design storm. The six OPCs budget $1,068,530 of drainage, but the engineering basis is thin: only one of the six sub-estimates carries an extracted line-item breakdown, and in that one (Cole/Diller) 83% of the drainage cost is a single lump-sum “Drainage improvements” line — the only sized conveyance element is a 6-in subsurface underdrain. No estimate cites a design storm or return period, even though the corridor’s regulatory design rainfall is fixed (NOAA Atlas-14: 25-yr 24-hr 4.25 in, 100-yr 24-hr 5.39 in [verified: connector]), and neither the OPC nor the 95% SPS grading & storm plan itemizes the detention/retention storage the post-development runoff requires (detention_shown: false) — echoing the corpus’s own extraction note asking whether the lump-sum items even include a detention basin. So the drainage line reads as a budget placeholder, not a design-basis quantity: a cost-completeness risk on privately-financed public infrastructure. This is a scope/design-basis reading, not a sizing of the roundabouts’ hydraulics (the corpus carries no footprint area). [verified: data/reference/hydrology/atlas14-corridor-ddf.yaml + watermark drainage-audit]

8. Project Dazzler — the parallel Tilted Gate thread

Tilted Gate LLC (Delaware; CSC agent; Montfort organizer; principals Randy Barrera and Timothy Chadwick) is running a separate project, “Project Dazzler,” with its own USACE Section 404 / 401 / wetland-mitigation track — and in a different county (Scioto). Same shell fingerprint and same engineer (EMH&T), different geography. [verified: data/extracted/permits/4081*.epa.yaml, data/extracted/permits/sos-tilted-gate-llc-2025-09-29.sos.yaml]

The Dazzler EPA application’s applicant contact, Randy Barrera, signed as randybarrera@google.com — a Google email address on the Tilted Gate / Project Dazzler filing. [verified: data/extracted/permits/4081890.epa.yaml] This is a direct Google↔Dazzler (Scioto) datapoint. On its own it would not attach Google to the Lima/Bistrozzi campus — but it no longer has to: the Lima attribution is independently established by the AEDG release and the PAAC and LACRPC minutes (§1, §6). What the google.com email adds is the connective tissue — the same Delaware-shell network (CSC agent, Montfort organizer) runs both the Lima (Bistrozzi) and Scioto (Tilted Gate) projects, and Google surfaces on both. The AEDG release names Google for Lima directly, in AEDG’s own words. [verified: data/extracted/aedg/aedg-data-center-release.release.yaml + PAAC/LACRPC minutes]

9. The professional network

A consistent advisory team sits behind the entities [verified: entity graph]:

• Counsel — Vorys, Sater, Seymour and Pease: Jill Tangeman (×11 contacts), Scott Ziance, Hannah Bragg (filer on the Bistrozzi Addition SoS registration).
• Organizer — the Delaware shells: Michael Montfort is the SoS organizer/manager of Magenta Capital & Tilted Gate — not Vorys counsel. A third-party investor profile ties this Montfort to Dallas–Fort Worth real estate and to Platon Investments LLC + Dynamo Ventures LLC (both TX, inc. 2025-05-29), sharing the cluster’s 2801 Centerville Rd, Wilmington PMB. [inference: aggregator-sourced; identity-resolution uncertain] Name-collision caution: a wsgr-michael-j-montfort-bio.pdf (Wilson Sonsini employee-benefits counsel, Washington D.C.) sits in the corpus but is probably a different Michael Montfort — it is not treated as the organizer or as campus counsel. [open]
• Civil engineering — EMH&T: Heather Dardinger, Melissa Queen Darby, et al.; also the site-plan engineer of record.
• GC — Turner Construction (Robert Zizzo) on the sanitary sewer.

10. Chronology (selected milestones)

[verified: watermark timeline]

11. Open questions & gaps [open]

The end user is no longer an open question — it is Google (§1, §6, §8). What remains open is below; the forward-looking questions (capacity, use cases, forecast) move from “gap” to the analysis itself — see the bigger picture.

• Beneficial ownership of the shells. Public records give registered agents and organizers, never the human principal behind the Delaware LLCs. The cluster is plumbing; who ultimately owns Bistrozzi (vs. who the campus serves) is unread.
• The withheld financials. The cost-benefit analysis, the School District Compensation dollar amounts, and the land-assembly purchase prices remain non-public by the County’s own choices (§6) — the figures that would price the deal.
• Compute capacity & use cases [analysis]. What ~275 MW of IT load and 36 cooling towers actually run — GovCloud / classification-level workloads vs. commercial — is the open analytical track, not a missing document. See Economics and the bigger picture.
• Resolution noise. A few contact entities remain coarse (the model occasionally merged two names or a name+firm into one field); see the graph.

12. Method & provenance

Every claim here derives from a committed artifact under data/extracted/**, produced by the ingest → extract → analyze pipeline (hybrid OCR+vision or text-first reads, Pydantic-validated, with self-reported confidence and warnings). The cross-document entity graph and timeline are deterministic functions of those artifacts (watermark entities, watermark timeline) — re-runnable and auditable. Figures transcribed from degraded scans may carry a ~ approximate marker; permit and instrument numbers are copied exactly. This dossier reflects the corpus as extracted so far and should be regenerated as new documents are ingested.