Attachments listed in source PDF: image.png Scott, Achieving smart growth requires holding data center developments accountable for their real- world water, energy, and environmental impacts. At the same time, local policy must recognize that digital infrastructure is critical infrastructure — essential to national security, economic resilience, and American leadership in artificial intelligence. To safeguard Spokane County's environment and resources without driving away important economic investment, Chapter 14.830 should focus on regulating objective, property-line impacts rather than imposing redundant, categorical restrictions. With that in mind, I'd like to flag the following provisions for the County's consideration. 1. Private well prohibition (SCC 14.830.190(2)) The draft currently bans Large-Load Data Centers from drawing any cooling or make-up water from private potable wells outright. Given that the ordinance already requires permanent metering of all withdrawal, reuse, and discharge (14.830.190(5)(a)), an annual public compliance report, and County/Ecology audit rights, I'd respectfully suggest that a blanket prohibition may be more restrictive than necessary to achieve the same goal. The Water Usage Effectiveness cap (0.3 L/kWh) and net-new aquifer withdrawal limits in 14.830.190(3)-(4) already govern how much water a facility can use. I'd ask that the County consider allowing private wells as a permitted source subject to those same metering and reporting requirements, rather than eliminating them as an option entirely — actual data center water consumption is often far lower than the public assumes, and metering the volume used is a more precise control than restricting the source. Real-world performance backs this up: Meta's Prometheus data center campus in New Albany, Ohio — built with direct-to-chip liquid cooling and air-assisted backup, a straightforward match for this draft's Closed-Loop Cooling System definition — reported total water withdrawal of approximately 86 megaliters (about 22.7 million gallons) for all of FY2024. Even accounting for the fact that this figure likely covers only a partial build-out well under Prometheus's eventual 1 GW target, the implied Water Usage Effectiveness is in the range of 0.03–0.07 L/kWh — an order of magnitude under this draft's 0.3 L/kWh cap. A facility performing at that level poses no meaningfully different risk whether its water comes from a municipal source or a metered private well; the volumetric cap and reporting requirements are what actually control impact, not the source itself. For comparison, a Five Guys burger restaurant in 3,000 sf of leased space uses over 1 Million gallons of water a month to blanch french fries in one of its Spokane County locations. Irrigating a 100-acre field corn crop in Eastern Washington requires approximately 217 to 267 acre-feet of water (70 million to 87 million gallons) per season. An 18-hole golf course in Spokane County typically uses between 40 million and 60 million gallons (123 to 184 acre-feet) of water per irrigation season. 2. 1,000-foot setback (SCC 14.830.210(9)) The draft requires Large-Load Data Centers to sit at least 1,000 feet from the nearest residential or commercially zoned property line. That distance is far outside what other major data center markets require. Looking at setback standards in three of the largest data center hubs in the country: Goodyear, AZ (home to Microsoft's PHX10/PHX11/PHX70 campus) — city planning staff have indicated at a June 2026 work session that the city intends to adopt a 300-foot separation from residential uses specifically for data centers, with hearings before the Planning & Zoning Commission and City Council this July. This standard is still in the adoption process and not yet codified, but reflects the direction the city is heading. Fairfax County, VA ("Data Center Alley," the largest concentration of data center capacity in the world) requires a 200-foot setback from residential property lines for the building itself, with a separate 300-foot standard for outdoor equipment like generators (Fairfax Zoning Ordinance § 4102.6.A(4), adopted September 2024). New Albany, OH (home to Meta, Amazon, Google, and Microsoft campuses along the "Silicon Heartland" corridor) requires a 100-foot enhanced setback with a landscaped buffer, including an earthen mound, where a data center faces residential property (New Albany Codified Ordinances § 1154.14). Averaging these three benchmark standards yields approximately 200 feet — still a substantial buffer, and one consistent with what the country's largest data center markets have determined is sufficient to protect residential areas. To further offset the reduced distance, the County could pair a 200-foot setback with a wider landscape buffer than currently drafted — for example, increasing the buffer requirement in SCC 14.830.210(11)(b)(i) from 25 feet to 50 feet and requiring a sound-blocking earthen mound within that buffer area, similar to the approach New Albany pairs with its own setback standard. This would strengthen visual screening and noise mitigation immediately adjacent to residential property without requiring the full 1,000-foot separation. I'd ask the County to revise SCC 14.830.210(9) to a 200-foot setback, paired with an expanded landscape buffer and sound-blocking mound requirement, rather than 1,000 feet. 3. Zoning district applicability (SCC 14.830.160(2)) The draft currently limits Large-Load Data Centers to a conditional use permit in the Heavy Industrial Zone only. Large-Load Data Centers should also be permitted in Light Industrial. Comparable jurisdictions bear this out: Goodyear, AZ zones Microsoft's data center campus as Light Industrial (I-1), and Fairfax County's comparable Bren Mar Park site was originally zoned Light Industrial (I-3) before being upzoned specifically to accommodate the project. I'd ask the County to open Light Industrial to Large-Load Data Centers under SCC 14.830.160(2) and 14.830.170 (Table 830-1), consistent with this trend. 4. Height, noise, and vibration standards (SCC 14.830.210(10), 14.830.180(3), and 14.830.180(1)(d)) The 60-foot height cap in SCC 14.830.210(10) is five feet more restrictive than the County's own Heavy Industrial standard. Per Table 614-2 ("Lot Standards for Industrial Zones," SCC 14.614.300), Heavy Industrial allows buildings up to 65 feet, with no stepped-height reduction near residential zones like Light Industrial has. Since Large-Load Data Centers are only permitted in Heavy Industrial (SCC 14.830.160(2)), I'd ask that SCC 14.830.210(10) simply match the County's existing 65-foot Heavy Industrial cap rather than adding a Data Center- specific reduction. On noise, the 50 dBA property-line limit in SCC 14.830.180(3) is stricter than Fairfax County, VA's 55–60 dBA standard, and the mandatory vibration study in SCC 14.830.180(1)(d) isn't required in Fairfax, Goodyear, or New Albany. I'd ask the County to align the noise limit closer to 55–60 dBA and reconsider whether the vibration study is necessary given none of these benchmark markets require one. 5. Equipment enclosures (SCC 14.830.210(5)) The requirement that equipment be housed in a metal-encased structure should be clarified to apply to IT hardware specifically, rather than sweeping in outdoor utility infrastructure like transformers, substations, and cooling units that are engineered for outdoor installation and wouldn't reasonably be enclosed. 6. Energy storage duration (SCC 14.830.180(5)) The 10-hour minimum storage duration effectively locks in a specific battery chemistry, and it misreads what on-site storage is actually for. A data center's UPS batteries exist to bridge the gap until backup generators start up — typically 3 to 15 minutes — not to run as a standalone power source for hours at a time. The 10-hour standard belongs to a different kind of system: the freestanding, grid-scale battery installations Fairfax and Goodyear regulate for solar-pairing and grid services. Neither of those jurisdictions, nor New Albany, requires a facility's own backup system to hold a set number of hours of charge. I'd ask the County to drop the fixed duration and instead govern storage through NFPA 855 safety standards and utility coordination. 7. Decommissioning financial assurance (SCC 14.830.210(1)(i)) Given that Large-Load Data Center structures are readily repurposed for other industrial uses, the financial assurance bond should be periodically adjusted to reflect the net remaining decommissioning obligation after accounting for facility salvage value, rather than requiring a bond sized to the full gross removal cost. I'm glad to provide additional detail or discuss any of these points further at your convenience. Thank you for considering these comments. Best, Daryn Ritz Project Manager (C) 509.710.7713 (O) 509.487.9792