My name is Steve Allen! I am a local tax payer and voter and I am terrified that the Spokane County Commissioners are not listening to us, to their constituents. I want to focus specifically on the language in the proposed Data Center Zoning Code so that any ambiguity and all loopholes are eliminated. This is how big Data Centers will exploit their power and force the locals who live here to pay and suffer. I am insisting that you pay CLOSE ATTENTION TO EVERY SINGLE WORD. If you do not, WE WILL BE HARMED. Specifically, you must eliminate the following words: "discretionary, nonbinding, infrequent, occasional." Nowhere should there be any words like "suggestions or suggested." All of the requirements need to identify who, what, when, where and how. Furthermore, noncompliance must be verified by outside parties and hold penalties. It is ridiculous to have the fox monitor the henhouse so do not allow the wealthy investor shell company to make their own assessments or evaluate their own progress. A Conditional Use Permit should not be expected to fix weaknesses that should have been addressed directly in the code. That is an egregious error that will impact the safety and wellbeing of your constituents' lives and steal the hard earned money they have invested in their homes and properties. You owe them your loyalty and protection, not Corporations, Shell Companies and billionaires who do not live, nor raise their families here. Groundwater protection, cumulative impacts, adequate infrastructure, monitoring, reporting and enforcement should be clear, articulated requirements, not something that can be interpreted differently from one application to the next. There are already many, many cities that have developed track records and data from current Data Centers that can be used to evaluate, compare and track compliance with. Also note how prior Data Centers made promises they did NOT keep. Again, who pays the price for that? Do Shell LLCs, the billionaires, the wealthy investors? No local taxpayers do. We pay for fire departments that will be rushing to put out fires in the 514 acre facility on the West Plains. Can you imagine what would happen if a fire escaped outside of the concrete walls onto the kindling dry fields of the West Plains? Have you driven through the neighborhoods ravaged by our recent fires here? The estimate of the damage is ONE BILLION DOLLARS. Who pays for that? People will not be able to get fire insurance policies now and you want to allow Data Centers to be built here anyway? Have you researched what Firefighters Unions now say about Data Centers? Do you know what their concerns and recommendations are? Who will pay for the Firefighters specialized equipment and trucks to put out electrical fires? Who trains them, who subsidizes their salaries? We do, not the Corporate Shell Companies. This is another obvious, egregious loophole for the Shell Company. We, the local taxpayers, subsidize their investment! That is outrageous and an egregious error that needs to be corrected. The size of the facility and the risk it poses to the ENTIRE COUNTY IF IT CAUGHT FIRE NEEDS TO BE INDEMNIFIED BY THE SHELL COMPANY WHO WILL BE MAKING A PROFIT! Add that to the criteria for approval. As multi-billion-dollar AI facilities increasingly spill into remote locations due to land and power availability, fire safety dynamics are fundamentally shifting. Both the regulatory landscape and hands-on response tactics have updated significantly to handle these massive infrastructure risks and you have not updated your language or expectations to meet the intense demands. These are some specific recommendations for you to do. 1. Stricter Battery Fire Safety Codes The rapid adoption of massive, high-density Lithium-Ion Battery Energy Storage Systems (BESS) inside data centers has forced strict regulatory updates. Local fire marshals enforce safety rules largely through NFPA 855: Standard for the Installation of Stationary Energy Storage Systems. [1, 2, 3] • Mandatory Hazard Mitigation Analysis (HMA): Data centers can no longer claim basic exemptions. They must provide custom, expert-backed HMAs that explicitly evaluate the risk of thermal runaway and deflagration from battery off-gassing. [1, 2] • Advanced Early Detection Requirements: Previous code editions limited fire detection to narrow air-aspirating or radiant-energy-only systems. The current standard broadens compliance to tie into NFPA 72 (National Fire Alarm and Signaling Code), explicitly approving thermal-imaging fire detection to catch cell-level overheating before visible smoke appears. [1, 2, 3] • Thermal Runaway Propagation Prevention (TRPP): New provisions mandate construction and physical spacing schemes to completely block a battery fire from cascading cell-to-cell or rack-to-rack. [1, 2] 2. Rural Fire Department Equipment & Operational Upgrades When hyperscale data centers launch in remote regions, they often outpace the volunteer fire districts assigned to protect them. An industrial fire requires thousands of gallons of water per minute—capabilities many small towns lack. In response, departments are using specific equipment and tech strategies to adapt: [1, 2, 3] • Procuring "Quint" Apparatuses: Rather than maintaining multiple trucks, smaller departments prioritize Quint fire rigs. These versatile trucks bundle a fire pump, water tank, hose bed, ground ladder, and aerial ladder into a single multi-tasking platform. • High-Capacity Flow Equipment: To supply the immense volume of water required to suppress a major data center cooling or battery failure, departments are adding hard suction hoses to vacuum water from local natural sources, paired with pumps that push at least 1,000 to 2,000 gallons per minute. • AI-Based Early Warning Systems: Rather than waiting for a standard phone call, rural districts are partnering with utilities to utilize advanced tools like 360-degree cameras. These systems automatically pinpoint coordinates and push live weather and satellite data straight to responders. • Modernized National Fire Data: Stations are transitioning to the National Emergency Response Information System (NERIS). This cloud-based network allows rural departments to swap intelligence and training strategies with large metropolitan departments that have experience fighting data center fires. [1, 2, 3, 4, 5] • Who pays for all of this upgrading? At this time, you are forcing the County taxpayers to pay for it. We the people are demanding you make the Data Centers and their investors pay. Otherwise, you are forcing the citizens to become the method to ensure the Data Centers maintain their profit margins. This is patently unfair, inequitable and inexcusable. Right now, Avista is trying to push through their price increases to fund their required expansion into hydrogen facilities to support AI Data Centers. Again, they are using the taxpayers to facilitate profits for AI Centers and that is inexcusable. Let the billionaires pay for their buildings and the infrastructure to support their company needs. My serious concerns are that you have NOT done nearly enough research on the risks posed by Data Centers. You are basing your recommendations from a couple of other departments in the County. That is not enough background or research, especially since Data Centers are so new and are just now developing track records to see how they have impacted the residents in their communities and the environment, the resources, notwithstanding the animals in that jurisdiction. Another obvious first criteria for acceptance of any plan from a developer MUST REQUIRE THEY HAVE A SUBSTANTIVE TRACK RECORD OF PRIOR BUILDS OF DATA CENTERS! This will give Spokane County residents and politicians the track record to review their behavior, compliance and responsiveness to the contract as well as to community needs. The idea that Al French allowed a Shell Company that was run out of Arizona who had no physical address and never built a single Data Center to be considered as a builder here, is mind boggling and challenges rational thought. We in this community demand that any Company, Corporation or Entity have an established track record of prior builds of Data Centers full stop. No exceptions. The Growth Management Act requires counties to include best available science when developing regulations to protect the functions and values of critical areas. This is non- negotiable and you are legally, ethically and morally responsible for ensuring that the plan you submit for approval meets those criteria. This requires you to be specific and detailed in every aspect to protect our rights, our health, our property, our community and the environment itself. It does not require you to create loopholes for large shell corporations representing billionaires. You must remain loyal to us, to the people who elected you, as well as to the best interests of those who did not. Make no mistake, highly educated professionals, lawyers, scientists, researchers, reporters, and influencers are watching you and reading EVERY SINGLE WORD YOU WRITE IN THIS DOCUMENT. We are identifying language in the DRAFT you publicized that concerns us and offering specific ways to strengthen it. Pay attention to us! As many of us have said to you both in writing and in person during your public hearings, we demand you close loopholes, define measurable standards and establish real, specific, tractable enforcement, with expectations and consequences before an application is submitted and before ambiguous language becomes a loophole where our lives are impacted, we become sick, our pets die, we lose our property value and nothing cannot be corrected. Saying you are sorry, you didn't know will not be an acceptable excuse. Remember, you still live here with us as your neighbors. We see you at shopping centers, going to the grocery store, getting gas and in restaurants. Do you think we will be forgiving when we know you were explicitly warned and you ignored our needs and instead cowed to the needs and wants of Shell Companies and billionaires? You have the opportunity to create an ordinance that is clear, enforceable and protective from the beginning. Don’t screw it up. Make every word count. Remember: WE LIVE HERE, BILLIONAIRES DON'T. Stephen R. Allen 2511 W. Maxwell Ave Spokane, WA. 99201