Fifteen questions for the Board Emerald ProjectCo Data Center Project Plan · Pittsburg County, Oklahoma · addressed to the chair, copied to the other two commissioners

1. Pittsburg County is asked to abate up to 85 percent of new value for twenty-five years. Childress County, Texas got IREN’s 750 MW campus on ten years, with a written “shall not extend beyond ten.”^C1C5C6
2. The minimum payments that would protect the county are introduced as a non-binding example, not intended to establish fixed or binding payment obligations. The 85 percent, the 25 years and the base value date are definite.^C1
3. Base value is the assessed value as of 1 January 2026, months before any vote, and stays frozen for the full term.^C1
4. The company may terminate the Tax Incentive Agreement on 90 days’ notice. No recapture clause is stated.^C1
5. The plan anticipates 40 jobs per phase and binds the company to none. Each Childress agreement requires “no less than ten.”^C1C5
6. The counterparty is Emerald ProjectCo Inc., a Delaware corporation formed 29 July 2025 and capitalised at ten dollars, whose Oklahoma qualification is signed by Will Roberts as President from IREN’s Childress campus. No owner is on any record and the plan names no guarantor. Childress bound five IREN companies jointly and severally.^C24C25C5
7. The plan is built on 1,200 MW. IREN tells its shareholders the Oklahoma campus is 1,600 MW on 2,000 acres. The top abatement tier starts above 550 MW per phase and carries the same illustrative minimum, so the extra 400 MW pays the county nothing more.^C1C11C13
8. Exhibits C and D, existing conditions and proposed improvements, are blank in the copy the county published.^C1
9. The plan never mentions 68 O.S. § 2902, under which the state reimburses local taxing entities for exempt manufacturing property, and the Tax Commission’s 2026 report lists NAICS 5182 data-center facilities among the qualifying categories.^C1C22C23
10. IREN closed FY26 with $5.90 billion of unrestricted cash, raised $11.0 billion in twelve months at a blended coupon under one percent, and tells shareholders its recent contracts pay back the cost of their GPUs in about two years. The county’s committee found the investment would “more likely than not not occur” without the districts.^C11C12C2

The plan is not carelessly drafted. Its problem is narrower: the terms that protect the county are labelled illustrative, and the terms that bind the county are already definite.

Read down the right-hand column. Everything definite sits on the county. The one definite obligation on the company is to report.

The company had a vehicle formed and qualified before the county’s committee met. The base value date falls between the two. And the county’s whole leverage, five signatures, is scheduled to be spent within sixty days of a vote.

Each question is phrased so the answer is either a document or an admission that there is none. The grounds line names where the fact behind it sits.

The counterparty

1. Who owns Emerald ProjectCo Inc., and will IREN Limited guarantee its obligations?

   The certified Oklahoma qualification is signed by Will Roberts as President, the name of IREN’s co-founder and co-chief executive, from IREN’s Childress campus address; it declares $21,100 of assets and ten dollars of authorised capital, and names no shareholder. IREN’s own list of significant subsidiaries does not include the company. In Childress County five IREN companies signed, each a party and all jointly and severally liable. The plan names one company and no guarantor.

   GroundsProject Plan · Exhibit 21.1 to IREN’s 10-K · Delaware file 10276559 · Oklahoma filing 2313901183 · Childress Phase 1 agreement^C1I2C24C25C5

2. Who has the county been dealing with, and does the officer who signed in Oklahoma stand behind the plan?

   The Oklahoma qualification is signed by Will Roberts as President and Jason Date as Secretary, and the registered-agent change by William Roberts; Jason Date does not appear in IREN’s filings. The plan was prepared with the county’s counsel and recommended by the committee. The record should say who represented the applicant at each step, and whether the president who signed in Oklahoma, or IREN Limited itself, will sign the Tax Incentive Agreement.

   GroundsProject Plan · committee recommendation of 21 April 2026 · Oklahoma filing 2313901183^C1C2C25

What binds whom

3. Will the Board adopt anything before the minimum payments are made binding, and will the Tax Incentive Agreement be published before the vote?

   The plan introduces its minimum-payment table as “a non-binding example,” “intended solely to demonstrate the general economic framework,” and “not intended to establish fixed or binding payment obligations.” The Economic Development Agreement and the Tax Incentive Agreement do not exist in public form.

   GroundsProject Plan, minimum payment table and § 12^C1

4. If the company terminates on ninety days’ notice in year three, what does the county recover?

   The plan lets the company terminate the Tax Incentive Agreement on ninety days’ notice and does not say what is recaptured. Childress County wrote cancellation and recapture, less payments made, into its agreements as the county’s remedy.

   GroundsProject Plan · Childress Phase 1 and Phase 2 agreements^C1C5C6

5. Why twenty-five years?

   Childress County abated for ten calendar years and wrote “shall not extend beyond ten” into the agreement. IREN built 750 MW there against 600 committed, on its own land, with its own substations.

   GroundsProject Plan § 8.5 · Childress agreements · IREN’s Childress site page^C1C5C6C13

6. Will the base value be reset to the adoption date?

   Base Value is the assessed value as of 1 January 2026, certified within ninety days of adoption and then frozen for twenty-five years. Every dollar of value added to the site since January is abated at up to 85 percent.

   GroundsProject Plan, definitions and § 8^C1

The numbers

7. If the company builds 1,600 MW rather than 1,200, what does the county receive for the extra 400?

   The plan’s cost tables, tiers and payment schedule assume two phases of about 600 MW. IREN’s annual report and site page describe the Oklahoma campus as 1,600 MW across 2,000 acres. The top tier begins above 550 MW per phase and carries the same illustrative minimum.

   GroundsProject Plan § 8.6 and § 10.1 · IREN FY26 10-K · IREN’s Oklahoma site page^C1C11C13

8. Will Exhibits C and D be completed and republished before adoption?

   Exhibit C, “Existing Uses and Conditions,” and Exhibit D, “Proposed Improvements and Uses,” are empty but for their headings in the copy the county published. The document meant to record what is on the land now, and what will be on it afterwards, says neither.

   GroundsProject Plan, Exhibits C and D^C1

9. Has the county asked whether this project qualifies under 68 O.S. § 2902, where the state reimburses the county, and what the county’s loss is under that route compared with this one?

   The plan does not mention § 2902. The Tax Commission’s 2026 report lists NAICS 5182 data-center facilities among the categories reimbursed from the Ad Valorem Reimbursement Fund, subject to an out-of-state revenue test, and notes that a NAICS code alone does not establish eligibility. The comparison is not on the record.

   GroundsProject Plan · 68 O.S. § 2902 · Oklahoma Tax Commission, 2026 Ad Valorem Annual Report^C1C22C23

10. Will there be a written jobs floor with a clawback?

    The plan “anticipates” 40 ongoing jobs per phase and binds the company to none. Each Childress agreement requires “no less than ten (10) new, full-time equivalent jobs.” Both counties’ documents already say permanent employment will be small.

    GroundsProject Plan · Childress Phase 1, 2 and 3 agreements^C1C5C6C7

11. Who pays for transmission and substation upgrades, and how much water is drawn, from where?

    Neither county document states who bears the grid costs or what the water demand is. In Childress the company put in its own substations. The Oklahoma plan is silent on both.

    GroundsProject Plan · IREN’s Childress site page^C1C13

Process and need

12. Have the five taxing entities been shown the plan’s own statement that the payments are illustrative?

    Kiowa Public Schools, the county, the Health Department, Kiamichi Technology Center and the Southeast Oklahoma Library System must sign the Tax Incentive Agreement within sixty days of adoption, and no district activates until all have. The Phase 1 distribution the plan shows them, $11.0 million to Kiowa Public Schools among it, is labelled non-binding.

    GroundsProject Plan, Tax Incentive Agreement clause and distribution table^C1

13. What evidence supported the finding that the investment “would more likely than not not occur” without the districts?

    IREN closed FY26 with $5.90 billion of unrestricted cash, raised $11.0 billion in twelve months at a blended coupon under one percent, tells shareholders its recent contracts pay back the cost of their GPUs in about two years, and built Childress on a ten-year deal. The committee’s finding is the statutory basis for the districts.

    GroundsCommittee recommendation, findings under 62 O.S. § 855 · IREN FY26 10-K and results release · Childress Phase 1 agreement^C2C11C12C5

14. When does the tabled resolution return to the agenda, and how many days before will the two agreements be published?

    The notice of 18 May 2026 set hearings for 8 and 22 June. No adopted resolution appears on the county’s resolutions page, and no revised plan has been published. The public should not learn the terms from an agenda packet.

    GroundsNotice of public hearings · Project Plan^C3C1

Water, power and noise

15. What water will the campus draw, from whom, what is in the loop, and where does it go when drained — and is the figure 0.6 million gallons a day or 9.1?

    The plan is silent on water. IREN told the McAlester News-Capital the loop is filled once, tops up at less than five households a year, disperses heat through air, uses no PFAS coolant, and would truck water in if local supply fell short, as at Childress, where its chief operating officer says the campus was filled with water “from outside the county.” None of that is in any document the county holds, no third party has measured the Childress draw, and under SB 259 a data center that buys water from a utility needs no permit and reports nothing. Will the Tax Incentive Agreement name the source and supplier, the initial fill and the annual top-up, the fluid and its disposal route, the number and permits of backup generators, and a noise limit at the property line?

    GroundsProject Plan · IREN Q&A, McAlester News-Capital · IREN’s chief operating officer on Childress · SB 259 and the water board’s director · the Greenbelt record^{C1C34C30C37C36C27}

The town next door

16. Was the committee ever shown the water figures the developer gave the Town of Kiowa?

    The plan is silent on water, but the developer was not. On 12 March 2025 it told Kiowa’s water office the project would use “anywhere from 0.6 MGD to 1.8 MGD,” and on 29 April 2025 that “the maximum water usage will be 9.1 MGD,” plus up to 81,000 gallons a day of potable water. In July 2025, asked for a will-serve letter for a site with “maximum 3000 people onsite,” the Kiowa Public Works Authority answered that it could give an estimate and not a letter. None of it appears in the plan, the committee’s minutes or its recommendation.

    GroundsTown of Kiowa records production, 14 Sep 2026 · Project Plan^54C1

17. What does the plan provide for Kiowa, which carries the load and sits outside both districts?

    The town says it wrote its own proposal after being advised during the county’s discussions that county-administered project funds “were not guaranteed to Kiowa,” the site being outside the town limits. A town of about 800 people would carry the traffic, the police and fire calls, the street wear and the utility demand. The plan apportions increment through the county’s own framework and names no share for the town.

    GroundsKiowa Community Impact and Infrastructure Partnership Proposal, 26 Jun 2026 · town’s production response · Project Plan^54C1

18. Who pays for the water and sewer upgrades the project requires of Kiowa?

    The town’s engineer estimated about $3.73 million of water improvements and $2.16 million of sewer improvements on 6 July 2026 to carry the added demand. The town asked the developer for $2.5 million up front and an annual partnership rising to $1,250,000 during construction, for the length of the twenty-five-year district. Nothing in the county’s plan commits anyone to any of it, and a utility that cannot recover the cost recovers it from its own ratepayers.

    GroundsISG opinions of probable cost, 6 Jul 2026 · partnership proposal⁵⁴

19. What did county officials arrange between the developer and the town, and was any of it before the Board?

    On 11 March 2026 the developer texted a Kiowa figure: “Commissioner Haynes provided me your contact details.” Mike Haynes chairs the Board and chaired the review committee then weighing the districts. On 20 April 2026, the day before the committee met, the developer gathered local business owners at the Kiowa police department. On 16 June 2026, six days before the public hearing, it asked the town for “a list of local supporters… willing to add their names” to an open letter addressed to the Commissioners. The town says it returned no list. Whether any commissioner or committee member was asked to sign, circulate or collect names is not on any public record.

    GroundsTown of Kiowa text messages and correspondence · Open Letter in Support of the IREN Kiowa Project⁵⁴

None of this asks the Board to refuse growth. It asks the Board to put the county’s protections in the same class of document as the county’s obligations. Each condition below is something Childress County, Texas already has in writing, or something the plan itself makes necessary.

• 01Strike “non-binding example” and write the minimum-payment table into the Tax Incentive Agreement as a floor.
• 02IREN Limited as guarantor, and every affiliate holding land or equipment in the districts jointly and severally liable, as in Childress.
• 03Base value set at the adoption date, not 1 January 2026.
• 04Term capped at ten years, with “shall not extend beyond ten.”
• 05Recapture on early termination, and a stay-in-place covenant for improvements, as in Childress.
• 06A written jobs floor with clawback, and a capacity minimum per phase.
• 07Exhibits C and D completed, and both agreements published at least thirty days before any vote.
• 08A § 2902 comparison on the record before the taxing entities are asked to sign.
• 09Water, power and generators in the agreement: source and supplier, initial fill and annual top-up, the fluid and its disposal route, generator count and permits, and a noise limit at the property line.

The Board of County Commissioners has three seats. The petition is addressed to the chair. The Kiowa site lies in Commissioner District 2, per the county’s own district boundaries.¹²

A district map with the three offices is on the Who to call page.

Markers beginning with C point into the numbered register on the Childress vs. Kiowa comparison; markers beginning with I point into the register on The IREN File. Every figure above is traceable through those registers to a filed document, an executed agreement, a company disclosure or a state registry. The two sources below are specific to this page.

1. [1]

   Pittsburg County — county offices directory, Board of County Commissioners

   pittsburg.okcounties.org · retrieved 4 Sep 2026

   Commissioner names by district, office addresses, telephone and fax numbers, email addresses and office hours.

   pittsburg.okcounties.org → offices

2. [2]

   OU Center for Spatial Analysis — Pittsburg County commissioner districts, 2020

   ArcGIS feature service Pittsburg_County_Data, layer 2 (comm2020_121) · the State Election Board’s mapping contractor · retrieved 1 Sep 2026

   That the Kiowa site, two miles south of Kiowa in Sections 25–27 and 33–35, T3N R13E, falls within Commissioner District 2.

   services7.arcgis.com → Pittsburg_County_Data FeatureServer