We are a coalition of organizations and individuals from across Kansas, dedicated to environmental stewardship and advancing clean energy across the state. We are concerned about the haphazard way large-scale data centers are being sited and built throughout the state, and we call on elected officials and regulators on the state, county, and municipal levels to implement a moratorium on new large-scale data center projects
until significant guardrails to improve transparency, local control, and responsible oversight
of such projects can be developed and implemented.

Large-scale data centers (defined as 75 MW or larger) are being planned and built very quickly, with little transparency or public oversight, and without taking into account the negative effects these facilities can have on our communities. Kansas residents across the state have pushed back, concerned about the impacts of large-scale data center development, and calling on candidates and elected officials at every level of government to demand corporate transparency and responsible local oversight. Elected officials and
regulators should empower communities with the necessary tools to enact appropriate safeguards against economic and environmental impacts from infrastructure, air pollution, water consumption, and emergency preparedness.

The Kansas WEALTH Coalition is in support of state and local policies that prioritize the health, safety, and welfare of Kansas communities, according to the following principles:

● Corporate accountability - Ensure that developers are transparent and accountable to host communities regarding impact on resources such as water and air. State tax incentives for data centers should be paired with local funding mechanisms to make communities whole for hosting high-impact facilities for the world’s richest corporations.

● Transparent third-party studies - Require transparent third-party studies of environmental and infrastructure impact prior to approval of large-scale projects, including evaluations of all costs (transmission, distribution, etc), noise, air quality, water availability, and other impacts to surrounding communities.

● Protect local water resources - Ensure that corporate water use does not compromise the long-term needs of Kansans. Closed-loop or other efficient systems minimize water usage, but require oversight to monitor water usage and impact on water quality, especially impacting the Ogallala Aquifer. These water-use constraints should include capacity covered by the largest water consumers in the state: coal, nuclear, and gas plants.

● Establish reasonable buffer zones - between hyperscale data centers and schools, hospitals, nursing facilities, and residential neighborhoods.

● Create meaningful public participation - through transparent notice requirements, public hearings, and opportunities for community input before major projects are approved.

● Support transparent review processes - including conditional use permits or equivalent procedures, so that each proposal can be evaluated based on its unique impacts and local circumstances.

● Bring Your Own New Clean Capacity and Energy - A single large-scale data center can use as much grid electricity as an entire city. The utilities industry expects a massive expansion of generation capacity from data centers over the next 10 years, and without a requirement to get that power from clean sources, this will likely mean a massive build-out of methane gas, as well as on-site diesel, poisoning the local community with dangerous emissions and contributing to climate disruption. We recommend an approach known as “(Bring Your Own New Clean Capacity and Energy)” (BYONCCE), which includes requirements that data centers generate or purchase their own clean energy and storage to serve their electricity and backup power needs. Demand response, load flexibility, and energy efficiency can also be qualifying elements of BYONCEE supply plans, freeing capacity from existing generation resources. Kansas needs safeguards on data center generators, paired with the development of affordable clean-energy solutions, so every Kansan can breathe clean air. Requiring data centers to meet every hour of their use through Evergy’s large-load tariff clean-energy option or similar power agreements at the co-op or municipal electric utility level can address these risks.

● Build to the highest energy efficiency standards - Data centers should be built to the highest energy efficiency standards to reduce further impacts on the electric grid. This will ensure that Kansas resources are being used efficiently and effectively for the lifetime of a data center facility.

● Transparent reporting - The industry standard for accountability and ongoing reporting on public water and energy use should be required.

● Fair labor standards - To receive state tax incentives the data center must have an apprenticeship program for workers registered with the US Department of Labor, pay prevailing wages, and perform work under a project labor agreement.

Polls show that 70% of Americans oppose rapid data center development; Kansans across the state have gathered together spontaneously to oppose them. Clearly, data center development requires more and better oversight, including the establishment of statewide guidelines for this industry going forward.

We are committed to working toward solutions that address our concerns and allow for development, but there should be a moratorium on the planning and building of large-scale data centers until the problems we’ve identified are addressed.