I am a property owner and business owner on the West Plains, 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. I have numbered my assessment and recommendations for easier tracking and follow up. 1. Specifically, you must eliminate the following words: "discretionary, nonbinding, infrequent, occasional, suggestions or suggested or reasonable." All of the requirements need to be precise, specific, identify who, what, when, where and how. Furthermore, noncompliance must be verified by outside parties and hold penalties and absolutely not be phrased as “may result in”. 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. When you do this you literally are showing them where you will be amenable to non- compliance. 2. 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. 3. 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. a. 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. b. 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. 4. 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? 5. Have you researched what Firefighters Unions now say about Data Centers? Do you know what their concerns and recommendations are? a. 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. b. 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. c. 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. 6. 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 been 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. 7. 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] 8. 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] 9. 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] 10. 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] 11. Rural Fire Department Equipment & Operational Upgrades. a. 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] b. 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. c. 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. d. 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. e. 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] 12. Who pays for all of this upgrading? At this time, by omitting specific language, you are forcing the County taxpayers to pay for it. a. 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. 13. Right now, Avista is trying to push through their price increases to fund their required expansion into hydrogen facilities to support AI Data Centers. a. Again, they are using the taxpayers to facilitate profits for AI Centers and that is inexcusable. 14. Let the billionaires pay for their buildings and the infrastructure to support their company profit margins and costs. 15. 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. 16. It is far too soon and too quick to make a judicious plan that adequately accounts and addresses the risks Hyperscale Data Centers pose. We can’t even conceptualize the totality of the multi-dimensional impact and harm they will cause at this time. 17. 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. a. 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. b. 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. 18. 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. 19. 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. 20. We are identifying language in the DRAFT you publicized that concerns us and offering specific ways to strengthen it. Pay attention to us! 21. None of you have articulated how these Hyperscale Data Centers will improve the quality of our lives. The best you’ve done and said: “it that it will bring jobs.” My research shows that: a. Jobs and crew are usually brought in from out of state. b. After construction for any Hyperscale Data Center there are only 20-100 people who are required to maintain the facility. c. Permanent Operational Jobs d. Direct Staffing: A typical large or hyperscale campus (exceeding 100 megawatts) usually employs only 20 to 100 permanent workers once operational. Highly automated facilities often run on skeleton crews of about 20 to 30 staff per 100 megawatts. [1, 2] e. Job Types: Permanent roles include data technicians, system operators, network engineers, security personnel, and basic facility maintenance. Many specialized or high-skill tasks are handled remotely or by traveling contractors. [1, 2] 22. How much income will the Hyperscale Data Center bring the County and since you are likely offering a huge tax break incentive, that reduces any income dramatically beyond property tax payments. 23. Why the rush? Why are you all breaking your necks to comply with billionaires who want to purchase large swaths of land in our community without vetting what the benefit to the local community is? Why did you only create a four month pause? Do you have NDAs that have timelines we are unaware of? 24. Daily news shows more problematic evidence that shows Data Centers are contaminating water aquifers and rivers, they are creating power surges and outages, causing human sickness and suffering. 25. https://futurism.com/future-society/fire-fighters-data-centers? fbclid=IwcGRvZgVleHRuA2FlbQIxMABicmlkETFGTzV3VHBYS0ZtNVVxYk8wc3 J0YwZhcHBfaWQQMjIyMDM5MTc4ODIwMDg5MgABHib0ECvzUb4q4VI_bIXmJ A7WI0QlEaZhUooUttOL1Q7ZJf5HWkOsvwoZga4c_aem_x9EsVZ8qZW3AmAP- 4WQjSg a. The fire department in Jerome Township, Ohio, an exurb northwest of Columbus, has grown increasingly annoyed at two Amazon data centers over the last four years. Since the first site was approved by local officials in 2021, first responders have answered a combined 84 emergencies between the two facilities, a rate of about two calls a month, according to The Columbus Dispatch. b. That’s on top of regular safety inspections. Whenever they arrive, fire officials and EMS workers say they’re met by facility security, who can make them wait as long as an hour for Amazon’s authorization to enter (data centers are critical to US national security, after all.) c. In April, local news reported a two-alarm fire at one of the facilities, which caused more than $50 million in damages and tied up first responders for over 24 hours. It’s a cushy deal for Amazon, which papered in a 100 percent property tax abatement lasting ten years for each site, meaning local residents are fronting the bill every time the fire department goes on a data center run. d. “That taxes our resources every time we go,” the township’s fire chief, Douglas Stewart said. 26. As many of us have said to you both in writing and in person during your public hearings despite only being given ONE MINUTE for public comment, 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! Sonya DeWitt, M.A., L.M.H.C. Cc: Amber Waldref, District 2 — awaldref@spokanecounty.gov Chris Jordan, District 1 — cjordan@spokanecounty.gov Josh Kerns, District 3 — jkerns@spokanecounty.gov Mary Brooks, District 4 — mbrooks@spokanecounty.gov Al French, District 5 — afrench@spokanecounty.gov