Data Center Interim Zoning

I appreciate the County’s Data Center Zoning Study with its comprehensive explanation of data centers, their characteristics, and impacts. I agree with the County’s conclusion that the potential impacts of data center development substantiate the emergency underlying the interim zoning and warrant additional action. I agree with the study’s recommendation that there be targeted, thorough, and protective zoning regulations addressing identifiable environmental and social impacts of data centers.
Data centers will be the subject of extensive legislation during the upcoming session, and it is appropriate to wait for the legislative outcomes and then extend the data center moratorium for another year pending development of appropriate County zoning regulations for data centers.
I appreciate the Climate Context in the study, stating that “Climate change is a significant threat to human and ecosystem health and well-being.” Unregulated data center development can greatly increase the use of fossil fuels for electricity generation, unacceptably increasing the climate degradation that is already underway.
Missoula County zoning regulations for data centers should:
1. Specify maximum size; for example, 20 MW.
2. Require that the data center either a) Supply 100% of its energy use with its own renewable energy or, b) Offset 100% of its energy use by purchasing new, renewable energy that produces the same number of Megawatt-hours as those used by the facility in a year. For example, a 20 MW installation operating continuously 24 hours a day consumes 175,200 Megawatt-hours (MWh) of energy annually. A 20 MW data center in Missoula County should be required to purchase new, renewable energy that would supply 175,200 Megawatt-hours annually.
3. Require backup generation be supplied by LDES battery instead of diesel or gas-powered generation. For example, a redox flow LDES battery can be powered up immediately if there is a loss of system electricity and is less expensive, in the long run, than fossil-fueled backup generation.
4. Require cooling by a closed loop system; prohibit the use of evaporative cooling
5. Prohibit on-site discharge of cooling system liquid or any other waste liquid that may be released during operation or periodic maintenance/renewal.
6. Require water use to be metered and the amount reported monthly to Missoula Valley Water Quality District or, for data centers outside the Missoula area, to other appropriate water quality authority. Even though these entities have no enforcement ability they could petition State authorities to enforce cutbacks in water use when impacts are significant.

We need to protect our air, water, quiet, darkness, wildlife, and health: I urge the county to make and enforce regulations that strictly limit the use of energy and water, and that strictly limit air, light, and noise pollution (particularly infrasound) with hard numbers. If data centers can't comply with human-centric pollution limits (and they won't) they should not be allowed.

Data centers in plenty of other communities (like Southaven, Mississippi) are already causing so much impact on residents that the data center companies are trying to bribe residents/buy them out of their homes so they don't sue the data center parent company. We can nip that in the bud here with strong limits on air, water, light, and sound pollution.

We shouldn't even be discussing solutions to people's concerns. Nobody wants an AI data center because we care about how much it will raise the cost of electricity and how it will contaminate our water and destroy our public lands. No matter what laws and regulations we try to enforce you can not trust that they will be transparent. They are going to do whatever makes them the most money and whatever is cost efficient. They do not care at all about the drain on our resources. An AI data center will cause all of us so much harm.

Data centers should not be built in Montana and especially in Missoula county. Our natural resources are too precious to
Pollute. This is an expensive place to live and our community can compete with these big companies in regard to negotiating electricity. Do not build a data center in Missoula county.

Data centers do not belong in Montana. I do not wish for Missoula county to allow any data centers in county lines. Summer of 2025. Lolo creek dried up for the first time that I can ever remember. I do not wish to see this be a regular occurrence. We do not need to add additional noise pollution to our nature sounds. No data center.

As usual a very vague document and description. The city has already made up their mind. Like usual public input is outrageously disregarded. In the meantime we as tax paying citizens have to pay the price and we get nothing back other than higher taxes. I do not believe for one second if everyone in the city were to vote 'no' the city wouldn't still move forward. Its not like they manage the money we pay them well anyway with all the beat up roads and lack of attention to anything but is what is on THEIR agenda's not what is on the citizens agendas. If it moves forward, make the permanent regulations first, not later after the impact. Sure this is a great money maker for the city, but at what benefits to the tax payers? We are just inviting buig business into what used to be "The Last Best Place".

As usual, a useless document. The talking points are just that. The end result, predictable. I'm especially enamored of the "wait and see what the other guy does" suggestion.

This is an excellent draft. I have only one small suggested addition. Any approved data center gets Montana state law tax benefits, so including the economic impact of those benefits on local government revenue should always be included as part of any data center impact decisional assessment.

Have you heard the thi gs coming out of the mouths of folks who own these things? They literally want you to sacrifice water and well being to advance their own agenda and financial gains. They do not care about anyone except themselves and to approve of a single data center with that in mind is a gross assault upon humanity and the oath yall pledged when taking office.

All you need is common sense to know how destructive Data centers are to communities.
We are talking about what problems we are having and going to have by opening the door to more complex data centers.
Have you not looked into other states and their problems and this is after they let them in.
Which will be too late.
Watching are issues with drought and low river levels.
And who wants these camels tapping into are Auquifer.
And any pollution that these centers emit will join in our inversion.
And let's talk about the noise pollution that they will produce.
Human health problems and it will affect are wildlife.
So common sense tells me no money is worth losing what is left of our Montana.
And if we don't protect Montana no one will!

This new study supports everything constituents have been saying since the Bonner data center was proposed. We cannot afford a data center in Missoula county. We cannot navigate draughts, inversions, and the sustainability of our native flora and fauna while bearing the burden of this AI craze. We don't need data centers. We don't need AI. We need the river. We need clean air. We need peace and quiet. We need a future for our children and our children's children.
Thank you.

These data centers are very complex.
There are many problems that come with them. My main concerns are the air pollution they can generate.
Missoula has especially in the winter inversions.
And the water use where are they going to take water from.
Our aqufier
Needs protection
From data centers .
And there is no way they can stop the noise from emitting the sound
That will disturb not only humans but our wildlife needs protection also.
And I am sure there are a lot more problems that come with them. With no way out once you open the door. No amount of monies are worth these data centers.

These data centers are very complex.
There are many problems that come with them. My main concerns are the air pollution they can generate.
Missoula has especially in the winter inversions.
And the water use where are they going to take water from.
Our aqufier
Needs protection
From data centers .
And there is no way they can stop the noise from emitting the sound
That will disturb not only humans but our wildlife needs protection also.
And I am sure there are a lot more problems that come with them. With no way out once you open the door. No amount of monies are worth these data centers.

My questions concern anytime point of time at any data facility.
What size will this data center be or maximum future data Centers be permitted?
Discharge of wastes and water waste? What temperature at point of discharge? What chemicals, man-made or natural will be discharged. Will these Dara center be required to be tested for said waste, how often? Will they be required to do any and all clean up concerning the data center. And will they be required to take responsibility of full payments for clean up?
Thank you

Evidence Requirements for Future Data-Center Decisions

Persistence Analytics Group LLC appreciates Missoula County's work examining the potential infrastructure and environmental impacts of data-center development.

As the county moves from its impact study toward potential permanent regulations, I encourage consideration of a distinct issue: the evidence required before an applicant's infrastructure representations become the basis for consequential municipal decisions.

Projected electricity demand, water consumption, cooling requirements, utility availability and development schedules are not necessarily equivalent to verified operating capability.

An evidence-based standard could require applicants to distinguish documented commitments from preliminary assumptions, identify material third-party dependencies and establish when subsequent changes in equipment density, electrical requirements, cooling design, operating configuration or project timing require renewed review.

The objective is not to advocate for or against data-center development. It is to ensure that municipal decisions rely on evidence appropriate to the infrastructure assumptions involved, including a process for revalidation when those assumptions materially change.

Neil P. Osnato
Founder, Persistence Analytics Group LLC
Decision Assurance™ | Infrastructure Assumption Verification™

I strongly support the one-year pause on new data centers! However, I urge you to keep this moratorium in place until a full review of the economic, environmental, legal, and social impacts of data centers is fully understood!

As someone with over 35 years of experience in designing, implementing, and supporting information technologies (much of it "bleeding edge"), I can honestly say that AI technology is not sufficiently mature enough to be integrated at an accelerated rate into every aspect of our lives. Let me give you an example: I recently tested Google's AI engine, Gemini, to do research for a comment about a forest service decision to use unallocated taxpayer funds for a project under a Categorical Exclusion that was largely for the benefit of a private entity with a special use permit. The forest service management offered two examples of previous projects where this had been done and therefore considered it accepted policy. When I queried Gemini about one of the previous projects it came back with a very detailed answer which included a statement that congress had actually allocated funds within a certain year's budget for this project and that this was indeed accepted practice. When I asked Gemini to give me the year, bill number and line item granting these funds, it responded that it made up the entire answer and none of it was factual. It went on actually apologize (AI apologizing to a human seemed absurdly odd as in the conversations between Hal and Dave in 2001: A Space Odyssey) and admit that it couldn't find any detail about the specific project, so it just decided to make up an answer that met my criteria. This scenario should be ALARMING to everyone!! There are countless stories coming out now about rouge AI agents from various engines finding ways to circumvent software boundaries and gain direct access to information they shouldn't be able to see and then take actions without controls in place. We don't need this in Missoula County, Montana, or anywhere else until sufficient programming controls, laws, and limits on integration are put into place!

To the Missoula County Board of County Commissioners and Planning Staff,
I support Missoula County’s decision to establish a temporary moratorium on new or expanded data centers in unincorporated areas of the county. As an Environmental Science and Sustainability student at the University of Montana, I believe that decisions about large scale development should account for long term environmental impacts and the availability of natural resources, not solely potential economic benefits. I encourage the County to use this study period to develop strong, science-based regulations that protect local ecosystems and community well-being.
One of my primary concerns is the potential demand data centers place on water and energy resources. Data centers require substantial electricity to operate and may require significant amounts of water for cooling, depending on the technology used. In a region where water resources, aquatic ecosystems, and reliable energy infrastructure are important to both communities and the environment, these demands should be carefully evaluated before development is approved. The U.S. Department of Energy (2024) has highlighted the rapid growth in data center electricity demand, reinforcing the need to consider the cumulative effects of this industry.
I recommend that Missoula County establish clear requirements for developers to disclose projected water consumption, electricity demand, wastewater generation, and backup generator emissions. The County should evaluate both direct and cumulative impacts, including potential effects on local watersheds, air quality, energy infrastructure, and nearby residents. I also encourage the County to prioritize water-efficient cooling systems, water reuse where feasible, and energy strategies that minimize additional pressure on existing resources.
Additionally, future regulations should require transparent reporting and ongoing monitoring to ensure that actual resource use aligns with approved projections. Any new standards should be enforceable and include corrective measures if facilities cause unexpected environmental harm. Community members should also have meaningful opportunities to review proposals and participate in future land-use decisions.
I recognize that data centers can contribute to technological innovation and economic development. However, these benefits should not come at the expense of environmental health or the long-term sustainability of local resources. I urge Missoula County to maintain a precautionary approach and establish enforceable safeguards before permitting additional data center development.
Thank you for considering my comments and prioritizing the long-term interests of Missoula County residents and natural resources.

To the Missoula County Board of County Commissioners and Planning Staff,
I support Missoula County’s decision to establish a temporary moratorium on new or expanded data centers in unincorporated areas of the county. As an Environmental Science and Sustainability student at the University of Montana, I believe that decisions about large scale development should account for long term environmental impacts and the availability of natural resources, not solely potential economic benefits. I encourage the County to use this study period to develop strong, science-based regulations that protect local ecosystems and community well-being.
One of my primary concerns is the potential demand data centers place on water and energy resources. Data centers require substantial electricity to operate and may require significant amounts of water for cooling, depending on the technology used. In a region where water resources, aquatic ecosystems, and reliable energy infrastructure are important to both communities and the environment, these demands should be carefully evaluated before development is approved. The U.S. Department of Energy (2024) has highlighted the rapid growth in data center electricity demand, reinforcing the need to consider the cumulative effects of this industry.
I recommend that Missoula County establish clear requirements for developers to disclose projected water consumption, electricity demand, wastewater generation, and backup generator emissions. The County should evaluate both direct and cumulative impacts, including potential effects on local watersheds, air quality, energy infrastructure, and nearby residents. I also encourage the County to prioritize water-efficient cooling systems, water reuse where feasible, and energy strategies that minimize additional pressure on existing resources.
Additionally, future regulations should require transparent reporting and ongoing monitoring to ensure that actual resource use aligns with approved projections. Any new standards should be enforceable and include corrective measures if facilities cause unexpected environmental harm. Community members should also have meaningful opportunities to review proposals and participate in future land-use decisions.
I recognize that data centers can contribute to technological innovation and economic development. However, these benefits should not come at the expense of environmental health or the long-term sustainability of local resources. I urge Missoula County to maintain a precautionary approach and establish enforceable safeguards before permitting additional data center development.
Thank you for considering my comments and prioritizing the long-term interests of Missoula County residents and natural resources.

I am making my first public comment to implore you not to allow any further development of data centers in Missoula County. I thank you for recognizing the public concern that has been brought to your attention thus far. You have put an interim moratorium on development for one year, but I ask as a concerned citizen and community member that you withdraw the proposal all together.

It is Montana’s natural landscape and unassuming way of life that draws people in. To build a data center here is to undermine and destroy that beauty. Data centers have been shown to cause air pollution, energy demand, PFAS, noise pollution, water impacts, EMF exposure, heat pollution, fire risk, light pollution, E-waste, flooding risks, mineral exploitation, and nuclear power health risk (https://www.ehn.org/ai-data-center-health-impacts).

Northern Virginia has one of the most condense areas of data centers. Many health and environmental effects can be observed in that region. Increased water used to cool the computers puts a strain on water sources like rivers and groundwater, creating scarcity whilst simultaneously degrading the water quality through blowdown contaminants. To compromise groundwater is to compromise public health and safety. (https://www.frontiersin.org/journals/climate/articles/10.3389/fclim.2026.1648912/full).

Please look at how data centers are negatively affecting the towns they are built in. Artificial intelligence should not be elevated above the safety, health, livelihoods, and overall quality of life of community members. Artificial intelligence should not be prioritized over our natural resources. Please say no to data centers.

To Missoula County Council of Commissioners,

As a resident of Missoula, I support the moratorium and extra research being conducted to evaluate the environmental impacts artificial intelligence (AI) data centers have, and I oppose the implementation of any AI data center within Missoula County. The environment should be kept as a priority in this issue, and with research already claiming that data centers across the United States significantly contribute to carbon dioxide emissions, adding 105 million tons in the year 2023 (Guini, et. Al, 2024), adding another data center should be heavily reconsidered. If no regulations are found to reduce this amount of carbon emissions, the moratorium should be extended indefinitely. Disregarding the carbon emissions, the impact on public water quality and quantity, noise pollution, heat concerns, and other impacts already acknowledged within your project’s description should be enough to reconsider implementing data centers at all.

I would like to add that, not only is the environment impacted by data centers and the use of AI, but research suggests that cognitive function is also being negatively affected. Through a process called “offloading,” critical thinking, cognitive tasks, and memory are all decreased in an individual that uses AI (Abrams, 2026). For the sake of future generations, this should be accounted for when considering the implementation of data centers for AI.

I’m including links to the online sources I’ve used here today. Please take these into consideration when deciding future measures regarding data centers and artificial intelligence.
Thank you.

https://impactclimate.mit.edu/2025/03/20/investigating-the-ecological-impacts-of-data-centers/
https://sustainabilitydialogue.uchicago.edu/news/data-centers-pollution-and-the-communities-left-behind/
https://arxiv.org/pdf/2411.09786
https://www.apa.org/monitor/2026/07-08/ai-job-skills-thinking