The xAI Files · The recordsRachelandthecityPosted September 2026

The records · who told EPA the turbines need a permit

Every record behind "Who told EPA that xAI's turbines need a permit? The turbine industry did."

This is the paper the essay is built on. The heart of it is a petition the portable turbine industry sent EPA in December of 2025, asking to have machines like the ones at xAI's sites reclassified so they would not need air permits. I got it from EPA in September of 2026 and it is hosted here in full, exactly as EPA released it. Around it sit the two government statements that say the opposite of what that petition says, and the Mississippi file that shows what the state does and does not keep track of. Read them yourself. If I have got something wrong, these are the pages that will show it.

The pages that matter, marked up

Each one outlines the passage the essay relies on, in red, on the page it actually sits on. Tap to open the full image.

The COMET petition's cover letter, December 8th, 2025, sent certified mail to EPA Administrator Lee Zeldin, on letterhead carrying Life Cycle Power's addressThe supporter page: ten names, including Mitsubishi Power Aero, Life Cycle Power and Solaris Energy InfrastructurePetition page 5: because portable combustion turbines are a stationary source, they trigger state stationary source permitting programs that portable engines do notPetition page 16: those permitting programs require preconstruction approvalPetition page 17: Geoff Bland, Chair of the Steering Committee, gives his employer as Life Cycle Power at the same suite and phone number as COMET's letterheadPetition page 18: Eric Hiser as Air Counsel and Wes Younger of Trinity Consultants as Technical Consultant, above Geoff Bland's signaturePetition page 13: Trinity Consultants prepared the comparison of turbine emissions to engine emissionsPetition page 7: the law says EPA must answer within a reasonable time, and give a brief statement of the grounds if it deniesThe proposed rule, page 30: the 30 day warning before a turbine hits twelve months in one place goes to the turbine owner and the site operator, not to any agencyThe proposed rule, page 31: locking a turbine out stops the twelve month clock, but running it again in the same place counts every locked out day after allShelby County to EPA enforcement, June 9th, 2025: the turbine engines on site are temporary nonroad engines, not stationary sourcesMississippi Permit Board minutes, March 10th, 2026: the air division chief calls the 27 portable turbines mobile sources, exempt, and not part of the project being permittedThe amended agreed order, September 11th, 2026: Turbine No. 53 was never delivered to the Stanton Road facilityCorrection #2, sent September 15th, 2026: MDEQ inspected on September 14th and found Units 57 and 58 physically present, no longer in operationBi-Weekly Turbine Removal Report #3, September 9th, 2026, listing turbines retired and removed in the previous two weeks

The petition

The document the whole essay turns on, and EPA's letter releasing it to me.

Coalition of Mobile Electric Turbine Users · December 8, 2025hosted here

The petition, as EPA released it: 46 pages

This is the file EPA sent me, whole. The first two pages are EPA's own response letter from an earlier request by the Southern Environmental Law Center, dated January 23rd, 2026. The 44 pages after that are the records: the cover letter to Administrator Zeldin, the supporter page, the petition itself, and Attachment 1, which is the rule language COMET wrote for EPA to adopt. The petition asks EPA to classify portable combustion turbines as nonroad engines so that using them would not require a stationary source air permit. To make that case it states what the rules say today, and that is the part that matters: portable turbines are a stationary source, they "trigger state stationary source permitting programs" that portable engines do not, and those programs "require preconstruction approval." Note that the two quotes are eleven pages apart, on petition pages 5 and 16. The cover letter is signed by Eric L. Hiser as Air Counsel. Geoff Bland signs the petition as Chair of the Steering Committee.

The full production, 46 pages (PDF)

U.S. Environmental Protection Agency · September 17, 2026hosted here

EPA's letter granting my request in full

EPA released the records to me nine days after I asked. The letter states the split in its own words: 44 pages of records plus the 2 page response letter from the earlier matter. My street address is blacked out on this copy and nothing else is.

EPA's final response letter (PDF, 2 pages)

The two governments that said the opposite

Both of these were said while the petition was sitting at EPA.

Shelby County Health Department · June 9, 2025hosted here

The county tells EPA enforcement the turbines are nonroad engines

A resident filed a complaint about the Memphis turbines through EPA's national tip line. EPA routed it to the county, and the county's pollution control supervisor wrote back to an EPA enforcement officer that "The turbine engines that are on site are temporary ‘nonroad engines,’ not ‘stationary sources’, that have operated for under 365 days." He sent that same paragraph to EPA at least three times in 2025. These seven pages are the June 9th thread, taken from a larger EPA production. Complainant names and phone numbers were redacted by EPA before release, not by me. Government work addresses are left in.

The June 9th thread, 7 pages (PDF)

Mississippi Environmental Quality Permit Board · March 10, 2026hosted here

The state tells its own board the same thing

These are the signed minutes of the meeting that approved the Southaven permit. On page 11 the chief of MDEQ's air division tells the board that the twenty-seven portable turbines on site are "mobile sources" exempt under existing state rules from needing a permit to construct or operate, that this was clarified in a letter dated July 29th, 2025, and that "These turbines are not part of the proposed project under consideration." The permit the board went on to approve covers forty-one permanent turbines. I do not have the July 29th, 2025 letter. I have asked for it.

Signed minutes, 40 pages (PDF)

What Mississippi's turbine file says now

Three documents from September of 2026, all obtained from MDEQ.

Mississippi Commission on Environmental Quality · September 11, 2026hosted here

The amended order: the list of 69 is really 68

The amendment rewrites Appendix A, the list of temporary turbines at the Southaven site. It reports manufacturer nameplate ratings in place of the earlier figures, identifies the turbines already retired, and states that "Turbine No. 53 was never delivered to the Stanton Road Facility." So the list has 69 rows and 68 machines. Eleven of those are marked retired in this version, which leaves 57 still there.

Amended Agreed Order 7739-26, 9 pages (PDF)

Trinity Consultants for MZX Tech · September 9, 2026hosted here

Bi-Weekly Turbine Removal Report #3

The order requires a report every two weeks naming the turbines deactivated in that period. This one lists six as retired and removed. It is worth knowing who writes these: Trinity Consultants, the same firm that wrote the technical section of the COMET petition and that writes xAI's air permit applications.

Report #3 (PDF, 1 page)

Trinity Consultants for MZX Tech · September 15, 2026hosted here

Correction #2, and the inspection nobody had a record of

Two corrections in one email. The first is a typo fix: the pair of turbines reported removed should have read Units 57 and 58, not 56 and 57. The second is the one that matters. It says "MDEQ performed a site inspection on September 14, 2026" and that during that visit Units 57 and 58 "were physically present but confirmed to be no longer in operation." Those are two of the eleven units the amended appendix marks retired. Site personnel are recorded explaining that retiring a turbine has three stages: shutting it down, air gapping it, and physically removing it. The day before that inspection, the state told me in writing that it had no record of any inspection or site visit since August 1st. Both things are true. One is about the world and one is about a filing cabinet.

Correction #2 (PDF, 2 pages)

What the state told me it does not have

Mississippi Department of Environmental Quality · September 15, 2026

Three records requests, three answers

MDEQ's written answers to me. It keeps no records tracking the twelve month limit on those turbines, not by unit, not by group, not by site, and no serial numbers. And it had no record of an inspection or site visit since August 1st. This copy is hosted on the state line records page.

MDEQ's written answers, September 15th, 2026 (PDF)

U.S. Environmental Protection Agency · January 2026

The rule EPA put out five and a half weeks after the petition

EPA did not give the industry what it asked for. Under this rule a turbine on a trailer is still a stationary source. But EPA wrote a way out into it and left it switched off, saying the question deserves further investigation before rulemaking action is taken. It is free to read at the Federal Register.

91 FR 1910, at the Federal Register

Think I got something wrong? Check the records, then tell me. That's the whole point.