• Applicants must provide proof of long-term studies of comparable operating facilities, not projections alone.
• Independent, developer-funded third-party review of water, noise, traffic, and grid studies rather than reliance on applicant-provided studies alone.
• Minimum of five days' public notice for all filings and meetings, with meaningful hearings before rezoning or site plan approval and adequate time for residents to review technical materials.
• The ordinance should preserve the Board of Supervisors' discretion to deny a rezoning request even when an application satisfies every checklist item; rezoning is a legislative act, and meeting minimum standards should not create an entitlement to approval.

18. Annexation and Jurisdictional Risk

• Risk that city annexation (including irregular or 'shostring' annexation under Iowa Code Chapter 368) could remove a project from county zoning authority after county standards are adopted.
• Need for intergovernmental (28E) agreements between the county and cities to ensure consistent standards regardless of jurisdiction.

19. Related Standards for On-Site Renewables and Battery Storage

Data center campuses increasingly include on-site solar arrays and battery energy storage. The Zoning Commission's language should include:

• Total impervious surface limited to 20% of the property for solar and 25% for battery storage.
• A 50-foot height limit and a 1,320-foot (quarter-mile) setback from property lines and road right-of-way lines.

20. The Need for Strong Definitions

Weak or missing definitions are the single most common loophole in local ordinances. A developer facing a standard it does not like will argue its project is not a 'data center,' that its 'campus' is a series of separate small buildings, or that its cooling system is 'closed-loop' when it is not. The ordinance must open with a rigorous definitions section, including at minimum:

• 'Data center,' 'data center campus,' 'hyperscale,' 'colocation,' and 'edge facility' — defined by use and by campus acreage and aggregate power demand, not by individual building size, so phased or subdivided projects cannot evade thresholds.
• 'Closed-loop cooling system,' 'evaporative cooling,' 'potable water,' 'blowdown,' and 'water withdrawal' — so water claims are verifiable.
• Noise terms: 'A-weighted (dBA)' and 'C-weighted (dBC)' levels, 'L90 background baseline,' 'tonal noise,' and 'property line measurement.'
• 'Excess power capacity,' 'committed load,' and 'projected peak demand' — so the 150% capacity requirement is enforceable.
• Karst feature, 'sinkhole,' 'losing stream,' and 'spring' — tied to state geological survey mapping plus site investigation.
• 'Sensitive areas' thoroughly defined — non-participating parcels, public parks and wildlife management areas, karst areas, and similar protected locations.
• 'Decommissioning,' 'abandonment,' 'cessation of operations' (with a defined trigger, e.g., 12 consecutive months of non-operation), and 'site restoration.'