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DUBUQUE COUNTY BOARD OF HEALTH

DATE: Thursday, November 5, 2026

TIME: 5:00 PM

PLACE: Northeast Iowa Community College 8342 NICC Dr. Conference Room 104A Peosta, IA 52068

Microsoft Teams Meeting Join: https://teams.microsoft.com/meet/227956168665645?p=NimQDvCkIhXpJ8CYeN Meeting ID: 227 956 168 665 645 Passcode: hA6qh26P

Agenda

Review of Minutes

Dubuque County Citizens Data Center Health Impact Working Group: NOISE September 23, 2026 - Meeting Recording Unavailable

Presentations & Reports

Overview of Water Concerns - Dr. Dolter

Introductions - Allie White

Water Pollution Aspects of Data Centers with Mitigation/Prevention Recommendations - Dr. Cwiertny

Review of Allamakee, Jackson, Linn, Sierra Club, Dubuque Data Center Water Quality Relevant Ordinance Recommendations - Dr. Dolter/Data Center Rep

Questions from the Audience

Public Comment

At this time, anyone may address the Board on matters of which are of concern to that person. Please raise your hand, state your name and home address. Please be aware that the Board is limited in their ability to respond to such inquiries and lowa Code prohibits the Board from deliberating or acting on items not appearing on the agenda. Individual remarks are limited to three minutes.

Board Communication & Reports

Next Meeting - Pending (January/February Timeframe)

Adjournment

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[IGNORE_INDENT]

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Public Health Prevent. Promote. Protect.

Dubuque County Public Health Department

Citizen Data Center Health Impact Working Group

Meeting Minutes – September 23, 2026 | 5 p.m.

Board of Health

Sandra Larson, JD, BSN

Preeti Joseph, MD

Mitchell Edwards, MD

Lynn "Tut" Fuller, MD

Jeff Metcalf, MD

Jack Dolehide, DO

Kathy J. Dolter, RN, PhD,

Lieutenant Colonel, U. S. Army (Retired)

Dubuque County Emergency Responder Training, 14928 Public Safety Way Dubuque, IA & via Teams

Call to Order: Dolter called the meeting to order at 5:02 p.m. (in person & Teams).

Individuals Present:

Sandra Larson, BOH member

Kathy Dolter, BOH member

Jeff Metcalf, BOH member

Allie White, DCPH

Emma Hilkin, DCPH

Mike Wolter

Mick Wolter

Mark Hueneke

Randy McClain

John O’Brien

Darrell Kifer

Ann Morton

Lilly Hoefflin

Al Brus

Ann Brus

Review of Minutes

Joe Bradley

Gail Weitz

Stacey Killian

Arlona Fredrickson

Jessica

Sandy Stock

Steve Peake

Jessica Oberbrockling

MaryBeth Decker

Ron Decker

Mary Moody

Donna Humke

Bob Humke

Adele Lenane

Terry Morton

Dubuque County Citizens Data Center Health Impact Working Group: LIGHT September 2, 2026 Motion by Metcalf, seconded by Larson; approved unanimously.

Presentations & Reports

Noise Pollution and Potential Public Health Impacts

The PowerPoint on noise pollution and potential public health impacts is in the meeting packet.

Allamakee County Draft Ordinance

Included in the meeting packet.

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Data Center Accountability for the Citizens of Dubuque County Draft Ordinance Language

Included in the meeting packet.

Jackson County Draft Ordinance

Included in the meeting packet. Johnson County Draft Ordinance

Included in the meeting packet.

Linn County Draft Ordinance

Included in the meeting packet.

Sierra Club Model Ordinance

Included in the meeting packet.

References

Included in the meeting packet.

Public Comment

Arlona Fredrickson shared an experience from a friend who lives approximately one mile from a data center in Aurora, Illinois. After Fredrickson shared the DCA noise ordinance with her friend, her friend became emotional and expressed that having similar protections in place before the data center was built could have made a significant difference. Her friend estimates that she loses approximately 600 hours of sleep annually due to noise from the data center. She previously taught children in her home but had to relocate because the noise made it difficult for the children to learn. Over the years, she and others worked with the data center and the city to address the issue. The data center has since made changes that have improved the situation. Fredrickson noted that newer data centers appear to be incorporating more protections.

See Addendum A about a public comment from John and Kim Veach

Board Communication & Reports

Sandra Larson expressed concerns about the potential health impacts associated with the company and suggested that the company be required to provide no-cost health insurance to all county residents, as well as contribute several million dollars annually to the Dubuque County Health Department.

See Addendum B about Noise Pollution reports.

Next Meeting – Time & Date Pending- Water

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FW: No Data Centers

From Kathryn Dolter <KathyDolterlowaVet@outlook.com>

Date Sat 9/26/2026 8:27 AM

To Allie White <Allie.White@dubuquecountyiowa.gov>

Cc Emma Hilkin <Emma.Hilkin@dubuquecountyiowa.gov>

Allie

I also received the message below regarding data centers.

What are your thoughts about it including it in the public comments for the Noise meeting?

Kathy

Kathryn J. Dolter, RN, PhD, Lieutenant Colonel, U. S. Army (Retired)

E-mail: KathyDolterlowaVet@outlook.com

Phone: 563-542-2940

If you can, or you think you can't, you're right! – Henry Ford Do what you can, with what you have, where you are. – Teddy Roosevelt

From: John and Kim Veach <kjveach@yousq.net>

Sent: Friday, July 31, 2026 2:10 PM

To: kathydolteriowavet@outlook.com

Subject: No Data Centers

Hello,

Please take time to read my information on data centers. I have included my sources. My intention is to give solid facts on why data centers aren't what we want or need! This project will affect all Dubuque residents, regardless of their proximity to the proposed site.

The minimal benefits of hosting a data center in Dubuque do not outweigh the significant risks to our water supply, electrical grid, public health, productive farmland and environment. Negatives are being seen and felt in communities that already have data centers. The biggest thing I am concerned about if the health impacts a data center will have on the people.

According to (Sightline Climate), nearly half of the data centers planned for 2026 have already been delayed or canceled. These data centers are drawing increasing scrutiny.

Rather than rushing into this, we should observe and learn from their experiences first. Technology changes constantly, down the road hopefully they will use less and fewer resources. Experts are saying these centers are not environment friendly today.

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Please consider the following resources:

( energy.gov) their most recent study says that data centers in 2023 consumed 4.4% of all electricity in the US and are expected to triple that by 2028.

Energy and water usage is tremendous.

(wri.org) World Resources Institute- A single modern AI data center can use as much power as 100,000 homes, many of the larger ones now being built are expected to consume up to 20 times that amount. A mid-sized facility can use up to 300,000 gallons of water a day, while large facilities can consume as much as 5 million gallons daily.

Experts globally like the United Nations, “warn us we have entered into an era of global water bankruptcy.”

( centers.lbl.gov) "It is estimated that less than a third of data center owners and operators in the U.S. measure and track water consumption." So numbers are likely way higher.

(iea.org) Data Center Electricity Consumption Growth- “Electrical data Consumption is up 130% in the US compared to the 2024 level.” Largely due to data centers.

Residential EMF exposure is rising because of the rapid expansion of energy-intense data centers that demand new high-voltage transmission lines, increasingly being built near homes and schools. (David Carpenter in Environmental Research) “The evidence that magnetic fields increase the risk of cancer is neither inconsistent nor inconclusive. Furthermore, adults are also at risk, not just children, and there is strong evidence for cancers in addition to leukemia, particularly brain and breast cancer.”

For constant operation nearly all centers have diesel generators on-site. Diesel generators emit several harmful air pollutants, such as nitrogen oxides, carbon monoxide and particulate matter.

Noise-centers emit low frequency noise. Nearby residents report that the constant noise generated by some data centers affect their well being. Total noise is highly hazardous.

( nidcd.nih.gov ) sounds at or below 70 decibels are generally safe.

(ℒesi.org) Data centers are becoming noisier as developers stack more information technology equipment and servers into smaller spaces. the compounding effect of thousands or tens of thousands of servers in a computing warehouse can raise noise levels to 96 decibels.

Clayton Tucker, who is running for Ag Commissioner of Texas says; cows, sheep and goats lose 30% of their body weight. Chickens lay 50% less eggs. A farmer North of Dallas, claims his cattle have only had stillbirths since a data center went in by him. Kids under 10 are starting to have heart problems. People over 40 years old are having heart attacks at higher rates and early onset dementia in 65 years and overall this within a 5 mile radius of centers.

Land usage: The large amount of acres they consume is a lot to lose for something that has highly negative impacts on communities, especially if it's highly productive farmland. (farmlandinfo.org) "The United States is blessed with a remarkable productive agricultural landscape. Cropland, pastureland, rangeland and woodland support a regionally diverse food and farming system capable of ensuring domestic food security. Agriculture land contributes to state and local economies, supplies lucrative export markets, and bolsters the nation's balance of trade. These exceptional natural

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resources sustain valuable wildlife habitat, provide flood control and fire suppression, scenic views, and resources for hunting and fishing. This land also acts as an enormous carbon sink, drawing down carbon from the atmosphere, which helps combat climate change.

Heat- (abc4.com) and growtheflowutah.org Salt Lake City, May 7, 2026. "Box Elder County has found the combined thermal output of the center could release heat equivalent to 23 atomic bombs daily." Dr. Rob Davies, a physics professor at Utah State, prepared the analysis that estimates the energy footprint of the proposed data center is comparable to 40,000 Walmart Supercenters.

https://www.pbs.org/video/we-saw-what-ai-data-centers-dont-want-you-to-see-n1ewcf/ A great video to watch.

Why are journalists doing these observations instead of regulators? The administration right now is pro AI policies. With gutting of environmental and enforcement agencies, if journalists wouldn't be doing this would anybody?

Some information from the above PBS video:

The video shows the data center plant in thermal imaging, you see the tremendous amount of heat they are using.

A lot of secrecies happen with these centers.

Approx. at 12:24 minutes- The companies building these data centers almost always promise that they'll use renewable or nuclear energy when they announce their projects. When you look at the data most of what's being built right now is powered by natural gas. It said it'll be at least 2028 before renewable powered A1. Nuclear at least a decade or more away. These fossil fuel powered facilities generate fine particulate matter. Widely understood to be detrimental to human health. Approx. 16:34 minutes- They rely on a quick approval process for permits in the beginning, then they go for bigger permits once they're there. This strategy enables the center to get a foothold in the communities without public input. Small first, bigger latter so it makes it impossible to stop them later. Approx. at 18 minutes- Massive amounts of air pollution. Creating health impacts like respiratory, cardiovascular, children and elderly with asthma are affected.

Approx. 19 minutes- So much unseen in these operations, are their permits appropriate? Are private energy grids sufficiently regulated for safety and pollution?

My personal thoughts:

Two things people need to survive is clean water and air, let's not mess with this.

This quote from a person at the Palo, IA council meeting I watched says a lot. “We can not drink data and we can’t eat money.”

Let's not make major mistakes we can never change. All because we didn't wait and learn from other communities' mistakes. Technology changes so quickly, if we wait things will be more environmentally friendly in future years. "Good things come to those who wait." Please say, NO to any large data center in Dubuque. Long term health concerns to our people and animals are a huge concern.

Thank you for your time in reading this letter.

Sincerely, Kim Veach 12216 English Mill Road

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Dubuque, IA 52003

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Subject: Concerns Regarding the Building of Data Centers in Proximity to Neighborhoods

Dear Concerned Citizens,

The purpose of my letter is to provide additional details and concerns about the construction of data centers built in proximity to residential neighborhoods. Our neighborhood in Aurora, Illinois, has experienced significant negative impacts. One particular data center was built adjacent to our neighborhood. This data center is less than 1500 feet from our property in Aurora, Illinois. It's directly in the backyard of one homeowner. (They call themselves ground zero!) When the data centers were first proposed, we were ignorant, trusting, and quite complacent about how they might impact us. We had lived in this neighborhood for over 30 years, and warehouses had surrounded us without much interference.

While I understand the importance of technological infrastructure and economic development, including the future need for data centers, data centers near neighborhoods raise several serious concerns. Some of these concerns relate to our quality of life, living conditions, increases in electricity and water bills, and potential air, soil, and water contamination. We still do not know how data centers will affect our current property values.

Noise Pollution - Constant Low Hum's and Vibrations

Data centers operate continuously and rely on large cooling systems that generate constant noise and low hums/vibrations. In our case, the chillers on the tops of the buildings and the generators create a constant low hum, and the decibels can often exceed acceptable noise levels. Depending upon the direction of the wind, we are frequently awakened throughout the night. Sometimes, we are unable to go back to sleep. At times, we use sound apps to reduce the noise from our bedroom. I have shared these videos with the city, the data center, and a local news channel. For example, I have captured videos that include the sound from our patio, which is adjacent to the data centers. The following dates and times represent some of these recordings: 9/17/25 5:57 am, 9/25/25 6:28 am, 9/30/25 6:28 am, 10/2/25 7:21 am, 10/8/25 2:14 am, 10/11/25 2:02 am, 2/4/26 6:49 am, 3/20/26 3:35 am, 3/22 5:48 am. On 3/26/26, tutoring a student with dyslexia at our kitchen table was extremely difficult. To provide additional evidence regarding the noise that day, we captured a short, 10-15-second reading. This reading was captured using the app, dB Meter. The dB-C scale is a frequency-weighting used in sound level measurements. Unlike dB-A, which reduces sensitivity to low and high frequencies, the dB-C represents a more accurate representation of a broad range of frequencies. It's often used when evaluating peak or maximum sound levels, especially in industrial or environmental noise assessments. The dB-C scale more accurately reports the low hum/vibration that we live through daily in our homes. See below for an example of a reading.

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	MIN	MAX	AVG
30Hz	-64.6824	-62.4076	-63.5434
764Hz	-64.6824	-62.4076	-63.5434
1493Hz	-64.6824	-62.4076	-63.5434
2232Hz	-70.6499	-61.7296	-65.1743
2966Hz	-70.6499	-61.7295	-65.1743
3700Hz	-72.0759	-62.8008	-66.024
4434Hz	-77.0766	-67.7205	-71.0849
5168Hz	-75.9431	-67.4027	-71.2627
5902Hz	-70.8674	-67.5845	-71.5202
6636Hz	-74.3076	-69.6645	-71.6655
7370Hz	-74.5381	-69.775	-71.6143
8104Hz	-80.9447	-76.2096	-76.5806
8838Hz	-75.9293	-71.0033	-74.0419
9572Hz	-79.9424	-75.7419	-78.3127
10806Hz	-83.4241	-79.1523	-81.1091
11040Hz	-84.4443	-81.1811	-82.7334
11774Hz	-85.1256	-80.8122	-83.353
12506Hz	-89.9828	-87.1061	-88.6917
13242Hz	-91.1117	-87.2176	-89.5261
13976Hz	-95.9867	-91.607	-93.9125
14710Hz	-105.184	-98.9298	-102.68
15444Hz	-110.298	-98.8225	-106.855
16178Hz	-116.212	-102.103	-112.213
16912Hz	-117.075	-107.121	-114.217
17646Hz	-117.416	-111.497	-115.608
18380Hz	-117.36	-113.038	-115.328
19114Hz	-118.704	-115.431	-117.292
19848Hz	-120.254	-116.717	-118.877
20582Hz	-121.766	-116.7	-120.354
21816Hz	-122.712	-119.738	-121.434

The continuous loud sound can be highly distracting, and working within our home office can be untenable. This constant low hum often has contributed to headaches, including migraines, and interrupted sleep over a sustained period. Adequate and uninterrupted sleep is an important priority for everyone. In addition, the constant noise and hum during specific periods have made our backyards intolerable. Our neighborhood provided specific sound readings and raised numerous concerns, which contributed to more stringent guidelines for future data centers in Aurora, Illinois. Unfortunately, the current data centers do not have to abide by these guidelines. Please refer to the link below for specific information.

https://www.aurora.il.us/Property-Business/Zoning-and-Planning/New-Data-Center-and-Warehouse-Regulations

Remediation

The data center has heard our concerns and is currently installing sound wails, sound-dampening boxes to cover the chillers, landscaping, and other on-site generators to reduce noise during testing phases. They have agreed to further adjustments to generator testing procedures. Examples include testing during daytime hours, shortened testing intervals, and testing two generators at a time. They have also installed sound-measuring equipment at their property line. These fixes have occurred after the data center was completed, at least one year later. Future data centers have already had these sound mitigation elements included during the building phases. It's important to note that future data centers are already making changes to reduce some of these negative impacts. Initially, the data centers in Aurora only had to follow the less strict guidelines aligned to warehouses.

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Environmental Impact – Electricity, Gas Fumes, and Water Consumption

Data centers consume significant amounts of electricity and water. These concerns raise issues about strain on local resources, especially during peak usage seasons or drought conditions. If data centers are built within drought-related areas, it causes further harm to the people living in those areas. There are many areas in the country that experience drought conditions. Additionally, our neighbors have indicated that diesel fumes affect them. All of this evidence provides a lengthy history regarding the negative sound/vibration and diesel fumes impacting our family and neighbors. Ongoing exposure to noise and industrial activity may have long-term impacts on residents' physical and mental health.

Vigilance and Safeguards

Each community must remain vigilant and ensure that regulations are in place prior to the approval of building permits. I encourage you to take the time to review the paperwork (building plans), ask questions (e.g., how water will be used, how waste products will be handled, how energy costs will be addressed, and how noise levels will be monitored). Aurora indicated that the data centers had a contract with our local electric company. Aurora stated that they didn't have any jurisdiction over the data center's contract and pricing; however, the residents' electric costs have increased. Why is ok for the data centers to pay a lower rate for electricity? Why do constituents have to pay an increased cost? Unfortunately, the city of Aurora approved a building plan that didn't include the current chillers on the top of the building. The citizens found out about this issue after the fact. It is these chillers that have created the noise pollution. Ask how many permanent jobs will be created and how much the city will benefit, economically. Often, there can be tax incentives for data centers that diminish these benefits. In summary, require a greater distance between these facilities and residential homes. Conduct thorough environmental and noise impact studies. Make sure there is ample sound and pollution monitoring paired with significant fines for violations. Reevaluate zoning and set back requirements for data centers. Most importantly, consider alternative locations better suited for these industrial uses when appropriate. Citizens pay the bills and elect government representatives. Let your voice be heard - loud and clear. The people matter.

Sincerely,

Julie Bay

Aurora, Illinois

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9/2/1/26

To Whom it may concern:

From: Phillip Reemtsma, D.V.M

Re: Data Centers- Impact on Livestock

My name is Phil Reemtsma and I am a livestock Veterinarian in Eastern Iowa. I have 28 years of experience working with cattle as a Veterinarian. I would like to discuss the potential impact a Data Center may have on cattle in regards to health, well being and productivity.

I think the most impactful harm that can come to livestock, especially cattle, could be from the constant noise emitted from a data center. Of the 4 primary senses of cattle, (sight, smell, hearing, and touch) hearing is the most sensitive of the 4. Constant noise (humming) has the potential to create chronic stress in livestock. Chronic stress from noise can elevate heart rate and increase anxiety in livestock. Chronic stress can also increase cortisol levels in livestock which in turn suppresses immunity. Suppressing immunity can lead to an increase in incidence of disease and decreased productivity.

There have been several studies done on constant noise over the years in livestock. I would refer you to work done in the 1980's by Heffner and Heffner for more information. In addition, I would refer you to a more recent article "The Role of Sound in Livestock Farming", published by the National Library of Medicine, July 14, 2023.

I will acknowledge more research needs to be done, especially concerning data centers and the effect of noise generated by them, however, I believe it also makes more sense to locate them in areas where they will have the least amount of potential impact on humans and animals until we have more information.

Phillip Reemtsma, D.V.M.

DeWitt, Iowa

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Dear Committee Members,

We at Rolling Hills Veterinary Services oversee animal health in Dubuque County, as well as the adjacent Jackson, Jones, Delaware, and Clayton counties. We felt it was imperative that our input be given as animal agriculture is a key component to the livelihoods and way of life for the communities in these counties.

Datacenters are a new and unproven addition to any community they are built in. The revenue they provide is known, however, the long-term environmental impacts are still not very well understood. What is slowly being uncovered is the excessive noise pollution, water pollution, and energy usage that these data centers demand. As veterinarians, our expertise lies in the effects datacenters may have on animals in the area, both pets and food producing alike.

Water is the most important nutrient in an animal's diet. There have been reports of wastewater from these data centers containing chemicals designed to inhibit bacterial growth within the systems, chemicals designed to prevent corrosion of these pipelines, and excessive heavy metals from the interior of these systems such as zinc, lead, and copper. All of which can be toxic to both pets, food producing animals, and wildlife. A strong majority of our food producing livestock receives its water from a single stream and/or a single well from a shared aquifer. Any downstream pollutants or strain on resources that this datacenter might cause could be catastrophic to our communities. The inability to provide clean and safe drinking water for livestock could result in lost livelihoods, extreme animal suffering, significant wildlife losses, and inevitably litigation to the county responsible for providing clean water to its taxpayer residents, not to mention the catastrophic effects those pollutants may have on the Mississippi River itself, or, the communities downstream of Dubuque County.

Data centers have been known to produce noise levels of up to 96 decibels. Studies have shown that constant noise above 65 decibels can induce increased heart rates, blood pressure, and stress hormones in the blood while anything above 85 decibels can cause permanent damage to human ears. While we are not experts in human medicine, we do know that animals, including dogs, cats, cattle, swine, horses, sheep, goats, and wildlife have a greater ability to detect sound at a lower volume than humans, and, at much lower frequencies. This means that any sound we hear, they hear louder. It also means that they can hear sounds we are unable to perceive. There have been studies performed on dairies indicating that a decibel level greater than 65 can cause an increase in stress responses from the animals. While that may not always be a perfect number for every species, it can reasonably be assumed that consistent noise levels will increase stress levels in livestock surrounding any proposed datacenter. Stress hormones will deplete an animal's body of

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the ability to ward off infections. It is very well known that the number one cause of respiratory disease in cattle is stress. From a livestock standpoint, constant stress on an animal will almost certainly lead to an increase in health issues. As for wildlife, there are a multitude of reports that go into the various ways that noise pollution can affect wildlife from both a health and ecological standpoint. A drug cannot go on the market prior to significant research and testing on the effects that it will have on the animals it is intended for. We at Rolling Hills do not believe that the animals in our communities should be among the first to learn the long-term effects of data centers.

As veterinarians we take an oath that states "do no harm". We feel that allowing a data center to be built in our practice area opens the door for potential harm to our patients and our community members. Whether it be through water pollution, water loss, or noise pollution, a datacenter could be catastrophic to our local economies and animal health.

The Veterinarians of Rolling Hills Veterinary Services

113 S Main St, La Motte, IA 52054 563-773-2771

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From Laura Wilging: Infrasound and Noise (and vibration, air, hazards)

1. Impact of infrasound and low frequency noise on human health and well-being. Part I: Review of experimental studies

ABSTRACT:

"This paper summarizes the currently available knowledge on the impact of infrasound and low frequency noise (LFN) on human health and well-being. This narrative review of the literature data was based on the selected, mostly, peer-reviewed research papers, review articles, and meta-analyses that were published in 1973–2022. It has been focused on infrasound perception, annoyance attributed to infrasound and low-frequency noise, as well as their effects on the cardiovascular system and sleep disorders. Particular attention was also paid to the latest research results and specific sources of infrasound and LFN, i.e., wind turbines. Med Pr Work Health Saf. 2023;74(4):317–32." (Source: Medcyna Pracy Workers' Health and Safety)

DOI: https://doi.org/10.13075/mp.5893.01354

PDF (may need translation): https://medpr.imp.lodz.pl/Wplyw-infradzwiekow-i-halasu-niskoczestotliwosciowego-na-zdrowie-i-samopoczucie-czlowieka,172195,0,2.html

2. Impact of infrasound and low frequency noise on human health and well-being. Part II: Review of epidemiological studies

ABSTRACT:

“This paper summarizes the currently available knowledge on the impact of infrasound (IS) and low frequency noise (LFN) on human health and well-being. This narrative review of the literature data was based on the selected, mostly, peer-reviewed research papers, review articles, and meta-analyses that were published in 1971–2022. It has been focused on the results of epidemiological studies concerning the annoyance related to infrasound and low frequency noise, as well as their impact on the cardiovascular system and sleep disorders. Particular attention was also paid to the latest research results and specific sources of IS and LFN, i.e., wind turbines. Med Pr Work Health Saf. 2023;74(5):409–23.” (Source: Medcyna Pracy Workers' Health and Safety)

DOI: https://doi.org/10.13075/mp.5893.01390

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PFD (may need translation): https://medpr.imp.lodz.pl/pdf-172194-97838?filename=Impact-of-infrasound-and-.pdf

3. "Health impact of environmental and industrial noise – a narrative review"

ABSTRACT:

“Industrial noise sources are among the environmental noise sources that are ranked second among the causes of ill health in Europe by the World Health Organization. The aim of this paper is to summarize and review of published information focusing on noise annoyance from industrial activities and mining. A search for articles was performed using the bibliographic databases platforms. The epidemiological evidence shows that environmental noise may be associated with cardiovascular and metabolic diseases, impaired cognitive development in children, mental health, post-irritability, and sleep disturbances. As a result of efforts to minimize the effects of industrial noise on human health, the New South Wales Environment Protection Authority published A Guide to the Noise Policy for Industry in 2017, which sets out recommended noise levels, methods, and procedures for noise management based on the latest scientific evidence. Social networks can be used to assess the population’s noise annoyance and to verify the effectiveness of the measures. The industrial noise sources are typically defined by low-frequency noise. Low-frequency noise has very low attenuation and is only slightly affected by obstacles, therefore it can be a major cause of night noise annoyance. An association was confirmed between exposure to low-frequency noise and sleep disturbance, psychological problems, cognitive impairment, increased social conflicts, anxiety, emotional instability, nervousness, and reduced mental performance – concentration, and visual perception. In view of the long tradition of mining and industry, the assessment of noise from these activities from the perspective of its impacts on human health is an inherent part of legislative processes. Med Pr Work Health Saf. 2024;75(5):425–431.” (Source: Medcyna Pracy Workers’ Health and Safety)

DOI: https://doi.org/10.13075/mp.5893.01491

PDF: https://medpr.imp.lodz.pl/pdf-190881-115421?filename=Health-impact-of-environment.pdf

Note related to migraine disorder:

Researchers increasingly view migraine as resulting from an interaction of predisposition and environmental exposures:

Genetic susceptibility + repeated environmental stressors + sufficient duration/intensity → increased probability of developing clinically manifest migraine.

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This is a biologically plausible model, but it has not been proven specifically for residential proximity to industrial complexes. (Nor has it been disproven, perhaps)

Environmental conditions that could theoretically contribute 1. Chronic environmental noise

Industrial complexes may generate:

Continuous mechanical noise Tonal noise Intermittent alarms Rail-yard operations Heavy truck traffic Loading and unloading activities

The best-supported pathway is likely:

Industrial noise → chronic sleep disruption + physiological stress → lower migraine threshold → possible increased long-term susceptibility.

Industrial and environmental noise is well established as a cause of annoyance and sleep disturbance, with growing evidence for broader health effects. (Source: ChatGPT with link to PubMed source)

AIR POLLUTION

Large industrial facilities may emit varying amounts of:

PM_{2.5}

PM_{10}

Nitrogen oxides

Sulfur dioxide

Volatile organic compounds

Ozone precursors

Systematic reviews have found that several outdoor pollutants are associated with increased migraine-related outcomes, although effect sizes vary and causality has not been established.

A plausible sequence is:

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Chronic air pollution → oxidative stress + systemic inflammation + neurovascular changes → increased migraine susceptibility. (Source: ChatGPT -to- PubMed)

1. “Migraine and air pollution: A systematic review”

“Results: The final review included 12 studies with over 4,000,000 participants. Designs included case-crossover, case-control, time series, and non-randomized pre-post intervention. Outcomes included migraine-related diagnoses, diary records, medical visits, and prescriptions. Rather than pooling the wide variety of exposures and outcomes into a meta-analysis, we tabulated the results. Point estimates above 1.00 reflected associations of increased risk. In single-pollutant models, the percent of point estimates above 1.00 were carbon monoxide 5/5 (100%), nitrogen dioxide 10/13 (78%), ozone 7/8 (88%), PM2.5 13/15 (87%), PM10 2/2 (100%), black carbon 0/1 (0%), methane 4/6 (75%), sulfur dioxide 3/5 (60%), industrial toxic waste 1/1 (100%), and proximity to oil and gas wells 6/13 (46%). In two-pollutant models, 16/17 (94%) of associations with nitrogen dioxide were above 1.00; however, more than 75% of the confidence intervals included the null value. Most studies had low to moderate risks of bias. Where differences were observed, stronger quality articles generally reported weaker associations.” (Source: PubMed)

DOI: https://doi.org/10.1111/head.14632

PMID: 37795754

https://pubmed.ncbi.nlm.nih.gov/37795754/ Erratum in

(**Correction to "Migraine and air pollution: A systematic review".

[No authors listed]

Headache. 2026 May;66(5):1202. doi: 10.1111/head.70053. Epub 2026 Feb 12.

PMID: 41681045 No abstract available.)

2. Ambient air pollution exposure and risk of migraine: Synergistic effect with high temperature

“Results: Higher air pollution levels were significantly associated with risk of migraine over various lag structures. In the best fitting lags, the odds ratio (OR) associated with an interquartile range increase of PM2.5, PM10, NO2, O3, and CO was 1.031 (95% CI: 1.010-1.053), 1.032 (95% CI: 1.007-1.057), 1.053 (95% CI: 1.022-1.085), 1.034 (95% CI: 1.001-1.067), and 1.029 (95% CI: 1.005-1.053), respectively. The SO2 effect was positive

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but not significant (OR 1.019 [95% CI: 0.991-1.047]). The PM effect was significantly stronger on high-temperature days (above the 75th percentile) than on low-temperature days (PM2.5, high: OR 1.068, low: OR 1.021, Pinteract = 0.03; PM10, high: OR 1.066, low: OR 1.014, Pinteract = 0.02).

“Conclusion: Our study provides new evidence that air pollution exposure may trigger migraine especially on high-temperature days, and this finding may contribute in establishing preventive measures against migraine.” (Source: PubMed)

DOI: 10.1016/j.envint.2018.09.022 https://doi.org/10.1016/j.envint.2018.09.022

PMID: 30245361

Chronic sleep disruption

Industrial environments may disturb sleep through:

nighttime operations,

lighting,

rail traffic.

backup systems,

shift-related activity.

Sleep disturbance is among the most consistently recognized factors associated with migraine attacks and may also influence long-term disease susceptibility through changes in hypothalamic-and-autonomic-regulation.-(Source: ChatGPT-to-Pubmed)

3. Migraine and the environment

Results: "Although some factors are controversial, migraineurs worldwide consistently report similar environmental triggers. However, few studies confirm environmental influences on migraine and headaches. Research to date indicates that migraineurs have lower thresholds for light-induced discomfort, sine grating distortion and illusions, noise tolerance and olfactory sensitivity compared to the general population."

Conclusion: "There are conflicting studies supporting the validity of patient-reported environmental migraine triggers. Prospective studies are needed to determine the extent that external stimuli influence the migraine process. Decreased thresholds for light, noise, olfactory and visual stimuli in migraineurs may be minimized by modifying the work, home and classroom settings." (Source: Pubmed)

DOI: https://doi.org/10.1111/j.1526-4610.2009.01443.x

PMID: 19545255

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4. Migraine is associated with altered processing of sensory stimuli

Abstract: “Migraine is associated with derangements in perception of multiple sensory modalities including vision, hearing, smell, and somatosensation. Compared to people without migraine, migraineurs have lower discomfort thresholds in response to special sensory stimuli as well as to mechanical and thermal noxious stimuli. Likewise, the environmental triggers of migraine attacks, such as odors and flashing lights, highlight basal abnormalities in sensory processing and integration. These alterations in sensory processing and perception in migraineurs have been investigated via physiological studies and functional brain imaging studies. Investigations have demonstrated that migraineurs during and between migraine attacks have atypical stimulus-induced activations of brainstem, subcortical, and cortical regions that participate in sensory processing. A lack of normal habituation to repetitive stimuli during the interictal state and a tendency towards development of sensitization likely contribute to migraine-related alterations in sensory processing.” (Source: PubMed)

https://doi.org/10.1007/s11916-014-0458-8

PMID: 25245197

Repeated activation of stress physiology

Living adjacent to persistent industrial activity may expose some individuals to chronic psychological stressors such as:

uncertainty

perceived environmental risk

persistent unwanted sensory stimulation.

Over time this could increase allostatic load—the cumulative physiological burden of chronic stress—which has been proposed as a contributor to disorders involving altered pain regulation. (Source: ChatGPT)

Neuroimmune activation

Industrial pollution can contribute to:

oxidative stress

endothelial dysfunction

inflammatory cytokine release

altered vascular function

Sensory processing overload

Migraine research shows that many people with migraine have increased sensitivity to:

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light {I might add: many have photosensitivity, and may also have visual auras, some of which could be (light-provoked) auras}

sound

odors

complex sensory environments

One hypothesis is that years of repeated multisensory exposure could influence central sensory processing in susceptible individuals. This remains speculative for disease onset. (Source: ChatGPT)

Odor exposure

Industrial sources may emit odors from:

chemical use

wastewater treatment

(petroleum refining and food processing)

diesel powered equipment

Systematic reviews of industrial odor exposure report associations with symptoms including headache, nausea, and stress, although odor itself is difficult to separate from coexisting environmental factors. (Source: ChatGPT with edits; National Library of Medicine/PubMed Central)

5. Industrial odour pollution and human health; a systematic review and meta-analysis

Results:

"Thirty studies were eligible for this review, mainly cross-sectional (n = 23). Only one study involved school-age children and two studies involved workers. Only five studies reported odour effects on objective laboratory or clinical outcomes. Animal Feeding Operations and waste were the most common industrial sources."

“The overall odds ratios in exposed versus not exposed population were 1.15 (95% CI 1.01 to 1.29) for headache (7 studies), 1.09 (95% CI 0.88 to 1.30) for nausea/vomiting (7 studies), and 1.27 (95% CI 1.10 to 1.44) for cough/phlegm (5 studies). Heterogeneity was a moderate concern. Overall, the body of evidence was affected by a definitely high risk of bias in exposure and outcome assessment since most studies used self-reported information.”

Conclusions:

“Findings underline the public health importance of odour pollution for population living nearby industrial odour sources. The limited evidence for most outcomes supports the need

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for high quality epidemiological studies on the association between odour pollution and its effects on human health." (Source: National Library of Medicine; PubMed Central)

https://doi.org/10.1186/s12940-021-00774-3

PMCID: PMC8459501

PMID: 34551760

Combined exposure model

Perhaps the most realistic hypothesis is that no single industrial exposure is responsible. Instead:

+Noise

+ Air pollution

+ Light at night

+ Odors

+ Sleep disruption

+ Psychological stress

+ Traffic

Higher cumulative environmental burden

This cumulative-exposure framework is increasingly used in environmental health research.

Current state of evidence

At present, the evidence supports the following conclusions:

There is good evidence that environmental conditions associated with some industrial complexes—particularly air pollution and chronic environmental noise—can adversely affect health, including sleep, cardiovascular health, and in some cases headache or migraine frequency: (Source: ChatGPT-to-PubMed)

6. Health impact of environmental and industrial noise - a narrative review

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Abstract:

“Industrial noise sources are among the environmental noise sources that are ranked second among the causes of ill health in Europe by the World Health Organization. The aim of this paper is to summarize and review of published information focusing on noise annoyance from industrial activities and mining. A search for articles was performed using the bibliographic databases platforms. The epidemiological evidence shows that environmental noise may be associated with cardiovascular and metabolic diseases, impaired cognitive development in children, mental health, post-irritability, and sleep disturbances. As a result of efforts to minimize the effects of industrial noise on human health, the New South Wales Environment Protection Authority published A Guide to the Noise Policy for Industry in 2017, which sets out recommended noise levels, methods, and procedures for noise management based on the latest scientific evidence. Social networks can be used to assess the population's noise annoyance and to verify the effectiveness of the measures. The industrial noise sources are typically defined by low-frequency noise. Low-frequency noise has very low attenuation and is only slightly affected by obstacles, therefore it can be a major cause of night noise annoyance. An association was confirmed between exposure to low-frequency noise and sleep disturbance, psychological problems, cognitive impairment, increased social conflicts, anxiety, emotional instability, nervousness, and reduced mental performance - concentration, and visual perception. In view of the long tradition of mining and industry, the assessment of noise from these activities from the perspective of its impacts on human health is an inherent part of legislative processes. Med Pr Work Health Saf. 2024;75(5):425-431.” (Source: PubMed)

https://doi.org/10.13075/mp.5893.01491

PMID: 39417331

There is moderate evidence that certain pollutants are associated with increased migraine-related healthcare use or symptom burden. (ChatGPT -to- PubMed): see again as per above "Migraine and air pollution: A systematic review" https://doi.org/10.1111/head.14632

There is insufficient evidence to conclude that living near a large industrial complex causes the onset of migraine disorder in people who would otherwise (may) never develop migraine. (source: ChatGPT)

Nevertheless, from a biological perspective, there are several plausible pathways—sleep disruption, chronic stress, neuroinflammation, cumulative sensory exposure, and gene–environment interactions—that justify further research into this question. (ChatGPT)

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7. Noise annoyance predicts symptoms of depression, anxiety and sleep disturbance 5 years later. Findings from the Gutenberg Health Study

Results: “General noise annoyance remained stable. Daytime noise annoyance predicted new onset of depressive, anxiety symptoms (also nighttime annoyance) and sleep disturbance (beyond respective baseline scores). Additional predictors were female sex, lower age and low socioeconomic status (SES). Regarding specific sources, daytime baseline aircraft annoyance predicted depression and anxiety. Sleep disturbance was most consistently predicted by neighbourhood annoyance (baseline and follow-up) and follow-up annoyance by aircraft (night) and road traffic (day and night).”

Conclusions: "We identified current and past noise annoyances as risk factors for mental distress and sleep disturbance. Furthermore, women, younger adults and those with lower SES are particularly susceptible to noise annoyance. Our results indicate the need to provide regulatory measures in affected areas to prevent mental health problems."

https://doi.org/10.1093/eurpub/ckaa015

PMID: 32034913 PMCID: PMC12477528

8. Occupational and Environmental Noise Exposure and Extra-Auditory Effects on Humans: A Systematic Literature Review

Abstract:

“Noise is a common harmful factor in our work and the environment. Most studies have investigated the auditory effects of noise exposure; however, few studies have focused on the extra-auditory effects of exposure to occupational or environmental noise. This study aimed to systematically review published studies on the extra-auditory effects of noise exposure. We reviewed literature from PubMed and Google Scholar databases up to July 2022, using the Patient, Intervention, Comparison, and Outcome criteria and Preferred Reporting Items for Systematic Reviews and Meta-Analyses guidelines to identify studies that reported extra-auditory effects of occupational or environmental noise exposure. Studies were evaluated utilizing validated reporting tools (CONSORT, STROBE) appropriate to study design. A total of 263 articles were identified, of which 36 were finally selected and reviewed. Upon conducting a review of the articles, exposure to noise can elicit a variety of extra-auditory effects on humans. These effects include circulatory effects linked to higher risk of cardiovascular disease and decreased endothelial function, nervous system effects correlated with sleep disturbance, cognitive impairment, and mental health problems, immunological and endocrinal effects connected to increased physiological stress response and metabolic disorders, oncological and respiratory effects associated with an elevated risk of acoustic neuroma and respiratory disorders, gastrointestinal effects linked to an increased risk of gastric or duodenal ulcer, and obstetric effects connected to the risk of preterm birth. Our review suggests that there are numerous extra-auditory effects of noise exposure on human, and further investigations are needed to fully understand these effects.” (Source: National Library of Medicine; PubMed Central)

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https://doi.org/10.1029/2023GH000805

PMCID: PMC10248481 PMID: 37303697

9. Assessing the Carbon Emissions and Energy

Consumption of U.S. Hyperscale Data Centers

https://arxiv.org/pdf/2606.05420

****IOWA is referenced; measured and contrasted, herein. ****

Authors and associations as per article:

"arXiv:2606.05420v1 [cs.Al] 3 Jun 2026

Gianluca Guidi,1,2,3 Francesca Dominici,1† Tiziano Squartini,3

Callaway Sprinkle, Jonathan Gilmour,1 Kevin Butler,4 Eric Bell,5

Scott Delaney, 6 Falco J. Bargagli-Stoffi1,7

1Department of Biostatistics, Harvard T.H. Chan School of Public Health,

Boston, Massachusetts, USA

2Department of Computer Science, University of Pisa, Pisa, Italy

3|MT School of Advanced Studies, Lucca, Italy

4Environmental Systems Research Institute, Redlands, California, USA

5Baxtel, Denver, Colorado, USA

6Department of Environmental Health, Harvard T.H. Chan School of Public Health,

Boston, Massachusetts, USA

7Department of Biostatistics, UCLA Fielding School of Public Health, Los Angeles, California, USA

†To whom correspondence should be addressed; E-mail: fdominic@hsph.harvard.edu

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Additional potential resources:

Vibration - Long-term effects of whole-body vibration: a critical survey of the literature - PubMed

Vibration - Occupational exposure to whole body vibrations and birth outcomes – A nationwide cohort study of Swedish women - ScienceDirect

Hazards. Notice: proprietary or secret chemicals (unknowns) could potentially be involved - 2024 ACGIH TLVs and BEIs: Chemical & Physical Agents Guidelines

*I couldn't access this entire Guidelines manual, perhaps your institution has access. I did see a partial list of chemicals around page 71 (and others) in a chart listed with a column including bodily effects.

Some table of contents curiosities may include:

pg. 179 - Ionizing radiation;

pg. 242 - effects of light;

pg. 130 – infrasound:

pg. 131 – audible sound;

pg. 82 – air particulate matter/particles;

pp. 137-143 – EMF's, microwave energy, radiofrequency.

Noise - Home - Acoustical Society of America

-Laura Willging

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Credible Scientific Research on Chronic Environmental Noise Exposure in Infants and Children

Evidence relevant to continuous, low-level, background, or mechanical humming noise—including considerations for hyperscale AI data centers

Evidence Summary

The strongest evidence concerns chronic environmental noise that is sufficiently intense, persistent, or intrusive to disturb sleep, increase stress/arousal, interfere with speech or attention, or otherwise impose a sustained auditory burden. There is much less direct research specifically on the continuous low-frequency mechanical hum of a hyperscale data center. It would therefore be scientifically inappropriate to claim that a data-center hum has been proven to cause developmental harm. However, the existing pediatric environmental-noise literature provides a strong scientific basis for investigating that question rather than assuming that a continuous background hum is harmless.

1. Systematic review — children's cognitive performance

Gheller et al., 2023/2024 — The Effects of Noise on Children's Cognitive Performance. This systematic review examined 26 studies involving primary-school children and cognitive/academic outcomes. The review found evidence that noise can interfere with concentration, learning, executive functions, verbal working memory, and academic performance. Particularly important, speech noise significantly impaired children's verbal working memory. Relevance to a data center: mechanical hum is not speech noise, so the finding cannot simply be transferred; however, it demonstrates susceptibility of children's cognitive systems to persistent acoustic interference.

Source: https://journals.sagepub.com/doi/10.1177/00139165241245823

2. 2025 systematic review/meta-analysis — children and adolescents

Fernández-Quezada et al., 2025 — The Influence of Noise Exposure on Cognitive Function in Children and Adolescents. This meta-analysis reviewed studies published from 2001–2023 and concluded that environmental noise has repeatedly been associated with adverse cognitive effects in young people, although strength of evidence varies by noise source and outcome.

Source: https://pubmed.ncbi.nlm.nih.gov/40137867/

3. Major systematic review — environmental noise and cognition

Thompson et al., 2022 — Noise pollution and human cognition: An updated systematic review. The review evaluated epidemiological evidence and concluded that evidence increasingly supports negative effects of environmental noise on human cognition, while emphasizing that strength varies by source and outcome.

Source: https://pubmed.ncbi.nlm.nih.gov/34649047/

4. Earlier systematic review specifically involving children

Clark et al., 2018 — A Systematic Review on Environmental Noise and Cognition. The review examined 34 studies involving children exposed to road traffic, aircraft, or railway noise and assessed cognitive outcomes.

Source: https://pubmed.ncbi.nlm.nih.gov/29414890/

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5. Long-term aircraft-noise study — reading and memory

Stansfeld et al., 2010. Chronic aircraft-noise exposure in children was associated with impairment in reading and long-term memory. The researchers proposed sleep disturbance as one mechanism connecting chronic noise exposure with cognitive impairment.

Source: https://pubmed.ncbi.nlm.nih.gov/20871180/

6. Landmark study — chronic environmental noise and cognitive development

Stansfeld et al., 2005 — RANCH study. Chronic aircraft noise was associated with poorer cognitive development, particularly reading comprehension. The authors characterized chronic aircraft noise as an environmental stressor capable of affecting cognitive development. Aircraft noise cannot be equated with a data-center hum, but the study provides evidence that chronic environmental acoustic exposure can have consequences beyond hearing damage.

Source: https://pubmed.ncbi.nlm.nih.gov/15936421/

7. Children, noise, stress and behavioral effects

Stansfeld, Clark et al. Reviews of pediatric environmental noise found associations with annoyance, reduced well-being, physiological stress responses, increased adrenaline/noradrenaline, and hyperactivity symptoms. The literature does not establish that environmental noise causes serious psychiatric disease; the more defensible conclusion is that chronic noise can act as an environmental stressor in children.

Source: https://pubmed.ncbi.nlm.nih.gov/26231366/

8. Sleep is particularly important in infants and children

Environmental-noise research demonstrates effects on sleep architecture, sleep continuity, physiological arousal, and daytime functioning. Nighttime noise can produce measurable biological changes and disturb sleep architecture. This is particularly relevant to a continuously operating facility because sleep is a plausible pathway through which chronic environmental noise could affect developing children.

Source: https://pmc.ncbi.nlm.nih.gov/articles/PMC4608916/

9. Infants are a particularly sensitive population

A 2024 systematic review of noise in neonatal intensive-care units found that all NICUs evaluated exceeded recommended cumulative sound levels. Reviews note that continuous noise from life-support equipment can be a significant acoustic exposure for premature infants. The American Academy of Pediatrics has recommended keeping NICU sound levels below approximately 45 dBA to promote optimal growth and development.

Sources: https://pubmed.ncbi.nlm.nih.gov/39363441/ ; https://pmc.ncbi.nlm.nih.gov/articles/PMC11137833/ ; https://pubmed.ncbi.nlm.nih.gov/28398915/

10. Newborn auditory exposure research

Pineda et al., 2017 — Auditory Exposure in the Neonatal Intensive Care Unit. The study quantified auditory exposure in NICU environments and evaluated environmental and medical factors affecting infant exposure. The significance is that researchers consider duration, intensity, developmental stage, acoustic characteristics, and physiological consequences rather than simply whether sound is loud enough to damage hearing.

Source: https://pubmed.ncbi.nlm.nih.gov/28189301/

11. WHO's broader environmental-noise evidence

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The World Health Organization treats environmental noise as a public-health exposure rather than simply a nuisance. WHO guidance addresses sleep disturbance, annoyance, cognitive effects, and cardiovascular effects. WHO updated its methodology for quantifying health impacts from environmental noise in 2024. Earlier WHO burden-of-disease work included cognitive impairment in children and sleep disturbance among noise-related health burdens.

Sources: https://www.who.int/europe/news/item/04-08-2024-how-much-does-environmental-noise-affect-our-health--who-updates-methods-to-assess-health-risks; https://www.who.int/europe/publications/i/item/9789289002295

12. Continuous background noise / white-noise literature

A 2024 paper examined potential developmental implications of chronic white-noise exposure in young children and raised concern that chronic exposure to continuous noise could potentially affect hearing, speech, and learning if sound machines are used incorrectly. This is not evidence that ordinary environmental background noise causes those outcomes; it underscores the importance of exposure intensity and duration.

Source: https://www.sciencedirect.com/science/article/abs/pii/S1389945724001588

13. Important counterpoint

Some controlled background noise can be beneficial in particular circumstances. A 2024 systematic review/meta-analysis involving children and young adults with ADHD or significant ADHD symptoms found that white/pink noise sometimes improved cognitive task performance. Newer research has also reported potential sleep benefits from white noise in infants and toddlers. Therefore, the scientifically defensible position is not that all continuous noise is harmful.

Sources: https://pubmed.ncbi.nlm.nih.gov/38428577/ ; https://pubmed.ncbi.nlm.nih.gov/41151421/

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Why a Data-Center Mechanical Hum May Require Specific Investigation

A continuous mechanical sound has different characteristics from aircraft flyovers, traffic, trains, or construction. A data-center acoustic environment may be continuous, contain low-frequency components, contain tonal components from fans/motors/pumps/compressors/electrical equipment, persist overnight, and be difficult for nearby residents to escape.

Recommended Acoustic Assessment

Measurement	Why it matters
LAeq	Average sound exposure
Lmax	Peak events
L10/L90	Background versus intermittent sound
1/3-octave bands	Identifies frequency distribution
Low-frequency noise	Relevant to mechanical systems
Tonal components	Fans/motors may create distinctive tones
Day/night measurements	Captures continuous overnight exposure
Indoor measurements	Determines whether homes experience noise intrusion
Seasonal measurements	Cooling loads change with temperature
Wind/weather conditions	Affect sound propagation
Distance measurements	Establishes actual attenuation
Pre-construction baseline	Essential for determining project-attributable change

Scientifically Defensible Statement for a Position Paper

There is substantial scientific evidence that chronic environmental noise can affect children's sleep, stress physiology, cognition, attention, learning, and well-being. However, direct epidemiological evidence specifically examining children chronically exposed to low-frequency mechanical noise from hyperscale data centers is presently limited. This evidence gap should not be interpreted as evidence of no risk; rather, it establishes a need for site-specific acoustic characterization, exposure modeling, baseline monitoring, and post-construction noise surveillance.

Key Sources for a Position Paper

Fernández-Quezada et al. (2025) — systematic review/meta-analysis of noise and cognition in children/adolescents.

Gheller et al. (2023/2024) — systematic review of noise and children's cognitive performance.

Thompson et al. (2022) — systematic review of noise and human cognition.

Clark et al. (2018) — systematic review of environmental noise and cognition in children.

Stansfeld et al. (2005) — chronic aircraft noise and children's reading/cognitive development.

Stansfeld et al. (2010) — chronic aircraft noise, reading and long-term memory.

Stansfeld (2015) — pediatric health effects of environmental noise.

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Sibrecht et al. (2024) — systematic review of noise in neonatal intensive care.

Pineda et al. (2017) — auditory exposure in NICUs.

WHO Environmental Noise Guidelines — authoritative framework for environmental-noise health effects.

Scope and Caution

This document summarizes scientific literature relevant to the question of chronic environmental noise exposure in infants and children. It distinguishes established findings from extrapolation and research gaps. It should not be used to claim that a particular data-center project has caused or will cause a specific health outcome without site-specific exposure measurements and appropriate epidemiologic or clinical evidence.

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WHY dB(A) ALONE CAN HIDE DATA CENTER NOISE

Measure the Full Sound. Measure in dB(C).

Data centers produce large amounts of low-frequency sound from cooling fans, chillers, transformers, and generators. Standard dB(A) measurements greatly underestimate this energy and the impacts it can have on nearby communities.

1. MEASURED DATA CENTER NOISE SPECTRUM Cooling Fan Dominated Facility

One third octave band measurements taken at a data center property line show strong low-frequency energy. A-weighting suppresses these frequencies.

A weighting reduces the measured level of the 118 Hz Inn tone by -20-25 dB. This is why dB(A) readings can appear "quot" when the hum is clearly audible.

Source: HVGC Engineering. "Analysis: Adding Sample Low-Frequency Trend Analysis to dBx." HVC Tech Note, 2021. Measured at a data center with cooling temperature. https://en.com/index-cs-lev-v்டا.zh-tw/addng-sample-low-frequency-tond-analysis-to-db/

4. A-WEIGHTING STRONOLY ATTENUATES LOW FREQUENCIES

Weighting curves from IEC 61672 show how dB(A) discounts low frequencies compared with d0(C). At 31.6 Hz, A-weighting is +36 d0 lower than C-weighting.

Weighting Difference (C - A)

Frequency (Hz) 51.5 63 125 250 500 1k 2k 4k 8k

C minus A (dB) 36 26 16 9 3 0 -1 +1 +1

Low Frequencies (Nearly Reduced by Avalighting)

Mid & High Frequencies (Title or No Reduction)

Source: IEC 61672-2013. Electricity could be used to provide constituents. Table values counted from standard A and C weighting curves.

5. COMMON DATA CENTER NOISE SOURCES

GOOLINGANS

DOHAKH NNST 63-75011

CHINA

Based on the company score 31-230114 TRANSFORMERS DIESEL GENERATORS COOLING TOWERS

TRANSFORMERS DESEL GENERATORS COOLING TOWERS

125011c hundringstod und formul随 (240 H, 340 Hz, etc.) Ereக்கland 1805 for发放 20<250 Hz 1000000000 112000 31-250 ft.

10000000000 20000 31-25014

Sources of Energy in International. "The Data Management Solutions. In Data Companies" Journalist News. https://energy@kinhatauniversity.com/access-of-heuristic-management-solutions/data-century Because of the low-frequency energy, the same sound can measure much higher in dB(C) than in dB(A).

2. THE SAME SOUND - TWO MEASUREMENTS

Because of the low-frequency energy, the same sound can measure much higher in dB(C) than in dB(A).

C-WEIGHTED (Capsules on Fingercards) A-WEIGHTED Resources Low Fingercards

70 dB(C)

50 dB(A)

The sound did not chango. A-WEIGHTED (Refections Law Frequencies)

Difference of 20 dB Low-frequency sound is largely ignored by dB(A).

Source: United on one-third of the land data from INVC Engineering (2021).

3. WHY LOW-FREQUENCY NOISE MATTEES

Travel for the Low-frequency sound travels long distances with less attenuation and personal buildings more easily.

Hard to block - It can pass through walls and windows and cause rattle and vibration of building components. Disturb sleep - Low-frequency noise is strongly linked to sleep disturbance and breakings.

Disturbs sleep - Low-frequency noise is strongly linked to sleep disturbance and awakening.

Health effects - Associated with stress, headaches, lesions, irritability and cardiovascular impacts.

Hard to mask - Low-frequency noise is much more difficult to mask with typical background sounds.

Source: World Health Organization (1999) Guidelines for Community Notes: Issuer of all (2014 Environmental Health Perspectives). Fields, J. M. (2013) “Review of the Effects of Low Frequency Noise,” Noise & Health, 15(14), 153-159.

6. WHAT COMMUNITIES AND REGULATORS ARE DOING

Communities are adopting octave band limits to address low-frequency noise from data centers.

The Ordinance is being updated to include overseLL bond noise standards to address concerns related to low frequency noise from data centers. - Prince William County, VA 2006 Ordinance Update, 2025

Industry and technological experts in ground monitoring and monitoring work

When prominent low-frequency components are present, noise measures based on A-weighting are inappropriate.* W14O Guidelines for Connectivity News, 1999

Technical guidance for data centers calls for octave-band analysis and C-weight-based reporting.

and C-weighted reporting. *Crave bond analysis allows you to identify and quantify the low-frequency components of noise that may be missed by a/a measurements.* - Larsen Davis, Data Center Noise Monitoring Guide, 2023

7. RECOMMENDATIONS FOR FAIR NOISE ASSESSMENT

MEASURE AND REPORT BOTH dB(A) AND dB(C) At all property lines, day and night. USE 1/3-OCTAVE BAND ANALYSIS At minimum 20 Hz to 8 kHz

1.厘船Whom County, VA. (1926, March 18). GO010. IIT N更新 Update Presentation. https://www.gov/news/2018-03/GO040710/0407100/Freerance/2018-03-07-0220012401202301.pdf

WesterLuish Organization, (1974). Oultinfor for Coromondy Place, WHO Regional Office for Europe. https://www.gov.uk/regards/Legislation/217

الرجال D瞳 (2023). Data Center Home Monitoring: Handling and Managing Low-Frequency N&C. https://www.gov.uk/data/events/news/information/news-monitoring/media-central-news-monitoring NIGHTTIME IMPACTS Low-frequency noise is more disturbing of night.

4.4.7. Kandahar, 4.4.7.1, 4.4.7.1, 4.4.7.1, 4.4.7

EVALUATE

RIGHTTIME IMPACTS Low-frequency noise is more disturbing at night

CONSIDER INDOOR MEASUREMENTS Low-frequency noise builds up to 1000 homes.

dB(A) is useful for many everyday sounds. But for data centers, it can miss the noise that matters.

Measure the full sound.

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Data Center Health Impact: WATER Concerns

Dubuque County Health Department Data Center Working Group November, 2026

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Agenda

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Review of Minutes

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Presentation

Overview of Water Concerns

Dolter

Water Concerns

Dr. Cwiertny

Review of Water Related Sections of Select Data Center Ordinances

Dolter

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Dr. Kathy Dolter Overview

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What Water-Related Concerns are Associated with Data Centers?

• Aquifer Depletion

Direct Water Use

Water Used Directly By Data Centers

Indirect Water Use

Water Used By Power Generation to Supply Power to Data Centers

Groundwater Quality Issues

Surface Water Withdrawals

Thermal Pollution of Surface Waters

Chemical Discharge

Indirect Water Use Impact

Stormwater Run-off

Wastewater Management

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What Water-Related Concerns are Associated with Data Centers?

“Aquifer Depletion

Reduced drinking water availability

Lower water tables for private wells

Reduced streamflow connected to groundwater

Addressed by Michael K. Anderson, P.E., Iowa Water Use Program – IA DNR

https://dubuquecountyia.portal.civicclerk.com/event/2752/files/attachment/16586

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Iowa's Water Use Program

State ( not federal) program.

Enacted in 1957 via Iowa Legislation.

In water rights law, Iowa is considered a hybrid between “Riparian” (Eastern U.S.) and Prior Appropriation (Western U.S.) law.

All waters in Iowa are “public waters and public wealth” of its citizens.

Use a permit system for anyone using >25,000 gallons of water per day, any single day of the year.

Data Center Water and Groundwater Impacts

Estimate ~2.2 billion gallons per year used in Iowa for cooling data centers.

Expected to more than double in near future (data centers currently planned in Van Meter, Cedar Rapids, Davenport, Council Bluffs...), as long as we continue to use our phones, laptops, watches, socials, smart tvs, etc.

Most will be liquid cooled and use municipal water for supply.

Data Center needs:

Power

Water

Infrastructure

Space

Water Availability In the Dubuque Area “May Be Limiting Factor”

Michael K. Anderson, P.E., Iowa Water Use Program – IA DNR

https://dubuquecountyia.portal.civicclerk.com/event/2752/files/attachment/16586

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What Water-Related Concerns are Associated with Data Centers?

"Groundwater Quality Issues"

...IF leaks, spills, or improper wastewater disposal occur, contaminants may enter soil and groundwater systems.

Corrosion/scaling inhibitors

Biocides

Chlorine compounds

Glycols

Heavy metals from piping systems

Refrigerants

PFAS chemicals"

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What Water-Related Concerns are Associated with Data Centers?

“Surface Water Withdrawals

IF data centers draw water directly from rivers, lakes, or reservoirs. Large withdrawals may:

Reduce streamflow during droughts

Affect aquatic habitats

Increase competition with agricultural and munic users

Alter seasonal water availability"

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What Water-Related Concerns are Associated with Data Centers?

"Thermal Pollution of Surface Waters

Reduce dissolved oxygen levels

Stress fish and aquatic organisms

Promote algal blooms

Cause long-term changes to aquatic ecosystems"

Page 45 Download HTML

What Water-Related Concerns are Associated with Data Centers?

“Chemical Discharge.

Cooling-tower blowdown water may contain:

Salts and minerals

Corrosion/scaling inhibitors

Biocides

Heavy metals from piping systems

Refrigerants

PFAS chemicals"

Page 46 Download HTML

What Water-Related Concerns are Associated with Data Centers?

"Indirect Impact"

Data centers also have a large indirect impact on water resources because electricity generation often requires water.

Thermoelectric power plants, including fossil fuel and nuclear plants, commonly use water for cooling.

Therefore, even air-cooled data centers may indirectly increase water consumption by increasing electricity demand (Siddik et al., 2021).

Researchers identified that nearly half of U.S. data center servers are powered partly by plants located in water-stressed regions (Siddik et al., 2021).

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What Water-Related Concerns are Associated with Data Centers?

• Stormwater Run-off

Eric Schmechel — Watershed Program Director

https://dubuquecountyia.portal.civicclerk.com/event/2752/files

• Wastewater Management

Not Yet Addressed

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Data Center Health Impact: WATER Concerns

Question Asked:

Does WATER Pollution Impact Health?

Does Data Center WATER Use Impact Health?

Questions Answered:

Does WATER Pollution Impact Health?

Does Data Center Water USE Impact Health?

National/Other WATER Standards

WATER Ordinance Examples

Proposed WATER Ordinance Requirements

Recommended WATER Ordinance Checklist:

WATER Pollution Prevention Included In Ordinance

Monitoring Requirement

Sanction(s) for Non-Compliance

Page 49 Download HTML

Data Center Health Impact: WATER Pollution

Question Asked:

Does WATER Pollution Impact Health?

Page 50 Download HTML

Data Center Health Impact: POTENTIAL Impact on WATER SUPPLY

• Question ASKED:

Do Data Centers Water Use Have an Impact On Health...Our Water Supply?

Page 51 Download HTML

Dr. David Cwiertny Presentation

Director, Environmental Policy Research Program, Public Policy Center

Researcher, Nanoscience and Nanotechnology Institute

Researcher, Environmental Health Sciences Research Center

Faculty Research Engineer, IIHR—Hydroscience and Engineering

Page 52 Download HTML

Data Center Health Impact: POTENTIAL for WATER Pollution

Question ANSWERED:

Does WATER Pollution Impact Health? YES

Page 53 Download HTML

Data Center Health Impact: POTENTIAL Impact on WATER SUPPLY

Question ANSWERED:

Do Data Centers Have an Impact On Health ... Our WATER SUPPLY?

YES

Page 54 Download HTML

Reminder: Health → A Result of Many Factors + Exposures Example Cardiovascular Disease

(Daiber, et al., 2025)

54 of 113

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Reminder: Health → A Result of Many Factors + Exposures Example Cardiovascular Disease

Environmental risk factors and cardiovascular disease

Climate change

Temperature extremes

Wildfires (PM2.5)

Hurricanes

Water pollution

Arsenic and copper

Lead and mercury

Nitrogen loading

Micro/nanoplastic

Chemical pollution

>16 000 chemicals

BPA, PCBs, PFAS, phthalates

Metals

Oxidative stress, inflammation

Endothelial dysfunction

Cardiovascular disease

Air pollution

Particulate matter

Ozone

Volatile organics

COx,SOx,NOx

• Nitrogen loading

Soil pollution

Poor microbial content

Low nitrogen content

Chemicals

Toxic metals

Micro/nanoplastic

Noise/light pollution

Traffic, construction, and industrial noise

Street and building lights, advertisement signs

Coronary syndrome, stroke, peripheral artery disease, heart failure, arrhythmias, hypertension

BPA, bisphenol A; COx, carbon oxide; NOx, nitrogen oxide; PCB, polychlorinated biphenyls; PFAS, per- and polyfluoroalkyl substances; PM, particulate matter; SOx, sulphur oxide; Piepoli M, et al. European Heart Journal.

Eu

Piepoli M, et al. European Heart Journal.

The content of this slide may be subject to copyright: please see the slide notes for details.

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National/Other WATER Standards

Clean Water Act of 1977

Safe Drinking Water Act

Water Pollution Control Act Amendments of 1972

Comprehensive Environmental Responses, Compensation, and Liability Act of 1980 (CERCLA)

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National/Other WATER Standards

• Library of Congress: Environmental Law - A Beginner's Guide

https://guides.loc.gov/environmental-law/federal-laws

Iowa Department of Natural Resources – Rules, Statutes, & Resources

https://www.iowadnr.gov/environmental-protection/water-quality/drinking-water/rules-statutes-resources

• University of Iowa Hubbell Environmental Law Initiative

https://heli.law.uiowa.edu/

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Dr. Kathy Dolter Ordinance Review: Water Related Concerns

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WATER Pollution Ordinances

• Allamakee, Iowa

Version: (4/17/26)

https://allamakeecounty.iowa.gov/wp-content/uploads/2026/04/Ord-L-Amendment-20-Data-Centers.pdf

Version: (8/17/26)

https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:f128cbc6-76ca-421a-a011-d151c23259a3?viewer%21megaVerb=group-discove

• Jackson County, Iowa

• Johnson County, Iowa

https://www.johnsoncountyiowa.gov/sites/default/files/2025-11/Omnibus%20UDO%20Amendment 10.13.25 PZC%26BOS%20PH%20Draft.pdf

• Linn County, Iowa

As of Date: 8/25/26

https://www.linncountyiowa.gov/DocumentCenter/View/27695/PA26-0001-Ordinance-PDF

Lucerne County, PA

https://www.dubuquecountyiowa.gov/DocumentCenter/View/8376/DCAD-Luzerne-Co-Data-Center-Ordinance-PDF?bidId=

Version 7.3

https://drive.google.com/file/d/1la4dtnUZnulhk5-Bs2w O6UAAcl2tp3c/view

• Sierra Club

• Data Center Accountability for the Citizens of Dubuque County

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WATER Pollution Ordinance Language Allamakee County Iowa

4. Water Quality Protections: LDCs shall not be built within 1000 feet of a known mapped sensitive area and shall not be built within 1500 feet of a sinkhole. LDCs built within 1/2 mile of a known sensitive area must adhere to a water protection plan, which shall include the installation and maintenance of a buffer strip of perennial grasses and/or native trees with a minimum 30-foot width around the sensitive area. The installation of the buffer around the sensitive area shall be performed by the Natural Resources Conservation Service (NRCS) or an approved 3rd party qualified to install and maintain buffers that control runoff. Reports of compliance shall be provided to the Zoning Administrator at the time of completion and every three years thereafter. The cost of installation and maintenance of the buffer around the sensitive area shall be incurred by the LDC owner. Any State of Iowa or a Federal Regulatory Agency water quality restriction which is more restrictive than that provided in this ordinance shall supersede this portion of the ordinance.

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WATER Pollution Ordinance Language JACKSON County Iowa

Section 7. Cooling Systems & Water Use

The purpose of this section is to address land use impacts associated with cooling systems and water use, including compatibility with surrounding properties, protection of groundwater and surface water resources, and site suitability for High-Density Computing Facilities. This section is intended to establish land use

standards and coordination requirements only. Nothing in this section shall be construed to supersede, duplicate, or replace the authority of the Iowa Department of Natural Resources or any other agency having jurisdiction over water withdrawal, discharge, wastewater, or related permitting requirements.

A. Required Cooling Technology

All High-Density Computing Facilities (HDCFs) shall utilize air-cooled or closed-loop cooling systems. Open-loop, once-through, or water-consumptive cooling systems are prohibited. This requirement applies to all primary and auxiliary cooling equipment serving computing, electrical, or energy storage components of the facility.

B. Limited Exception (Board of Adjustment Discretion)

The Board of Adjustment may consider an alternative cooling technology only if the applicant submits a certified engineering report demonstrating that the proposed system:

Does not withdraw groundwater or surface water.

Results in no net consumptive water loss.

Does not increase risk to aquifers, private wells, or hydrologically sensitive features.

Complies with all applicable Iowa Department of Natural Resources (IDNR) water-use and discharge requirements.

Any approval of an alternative cooling system shall require written Findings of Fact and may include conditions of approval.

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WATER Pollution Ordinance Language JACKSON County Iowa

C. Spill Prevention and Containment

All coolants, lubricants, and water-treatment chemicals shall be stored in approved containers with secondary containment sufficient to prevent release to soil, groundwater, or surface water. Containment practices shall comply with all applicable local, state, and federal requirements, including applicable IDNR or EPA requirements, manufacturer specifications, permit conditions, and applicable fire, electrical, or industry standards. [Revised from 5/18/2026 draft]

D. Cooling Water Discharge and Disposal

Any discharge or disposal of cooling water, including water containing additives or treatment chemicals, shall comply with all applicable IDNR, federal, and other legal requirements. Where cooling-water discharge or disposal is proposed as part of facility operations, the applicant may be required to provide sufficient information to demonstrate that such discharge or disposal will be lawfully handled through the appropriate permitting or disposal pathway. Nothing in this subsection shall be interpreted to authorize discharge otherwise regulated by IDNR or other agencies having jurisdiction.

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WATER Pollution Ordinance Language JACKSON County Iowa

E. Closed-Loop System Verification at Start-Up (Under Review)

Prior to commencement of full facility operations, the facility owner and operator shall provide written verification from a licensed professional engineer or qualified cooling-system installer that:

All closed-loop cooling systems have been pressure-tested or otherwise inspected for leaks and system integrity;

Testing and inspection were conducted in accordance with manufacturer specifications and applicable industry standards; and

Any deficiencies identified during testing have been corrected and re-verified.

The Zoning Administrator may require follow-up verification or inspection if there is credible evidence of leakage, system malfunction, or resulting impacts to neighboring land uses or environmental resources.

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WATER Pollution Ordinance Language JACKSON County Iowa

F. Annual Water Use Reporting

Unless the facility is connected to a municipal water-supply system, the facility owner and operator shall submit a simple annual water-use summary to the Zoning Administrator by March 1 of each year covering the prior calendar year of operations. The summary shall include, at a minimum:

Total water used during the reporting period, by source, including municipal supply, private well, or hauled water;

A brief description of any changes to cooling equipment, cooling-system type, or water-use practices during the reporting period; and

A certification that the facility remains in compliance with the cooling-system and water-use requirements of this section.

Routine submission of this summary to state agencies is not required by this ordinance. Additional reporting may be requested by the Zoning Administrator only if required by IDNR or if credible evidence of water-use conflicts with neighboring properties or environmental resources arises.

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WATER Pollution Ordinance Language JACKSON County Iowa

Section 8. Sanitary Facilities and Water Supply

This section serves as a coordination provision. Sanitary sewage disposal systems and potable water supply systems are governed by the County Health Department and applicable state agencies rather than independent County zoning standards.

All sanitary sewage disposal systems and potable water supplies serving a High-Density Computing Facility shall comply with applicable County Health Department regulations and all applicable state requirements administered by the Iowa Department of Health and Human Services, Iowa Department of Natural Resources, or any other agency having jurisdiction.

Where review or permitting by the County Health Department or a state agency is required, the Zoning Administrator shall coordinate referral as part of the application review process. Approval under this ordinance does not relieve the facility owner, operator, applicant, or property owner of responsibility to obtain all required sanitary, wastewater, potable-water, well, water-system, or related permits and approvals.

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WATER Pollution Ordinance Language JACKSON County Iowa

3. Facilities that cannot comply with the cooling and water-use standards of Section 7 without reliance on consumptive groundwater or surface-water use shall be ineligible for approval. Any request for consideration of alternative cooling technology shall be reviewed only through the Board of Adjustment approval process and the limited exception provisions of Section 7(B), and shall require written Findings of Fact.

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WATER Pollution Ordinance Language JACKSON County Iowa

High-Density Computing Facilities are also prohibited within the Floodplain Overlay District and within any area where industrial or commercial development is prohibited by applicable County, state, or federal law, regulation, easement, deed restriction, conservation restriction, or other legally binding land-use limitation. Sites containing or affecting wetlands, conservation areas, protected natural-resource areas, drainageways, flood-prone areas, karst features, bluffs, or other environmentally sensitive resources shall be subject to all applicable County, state, and federal review and permitting requirements. The County may require the applicant to identify such resources on the site plan and may require additional information or conditions where necessary to determine site suitability and prevent adverse land-use impacts. Sites located within areas mapped in the County's Historical Burial Mound Overlay or other known or potential archaeological or cultural resource areas shall be subject to the County's existing cultural resource review requirements. Where applicable, the County may require a cultural resource assessment prepared by a qualified professional to confirm that development will not disturb protected resources. Sites located within the viewshed of a designated national or state scenic byway shall be reviewed in accordance with the scenic byway and visual resource provisions of Section 12.

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WATER Pollution Ordinance Language JACKSON County Iowa

The applicant shall identify the proposed method of sanitary sewage disposal and potable water supply for the facility, including whether the facility will use an existing system, proposed private well, public or municipal water service, hauled water, or another lawful source. Any required County Health Department or state agency review shall be coordinated under Section 8.

5

The applicant shall submit a preliminary stormwater, grading, drainage, and erosion-control plan prepared by a qualified professional, identifying existing and proposed drainage patterns, impervious surface, stormwater facilities, erosion-control measures, sediment-control measures, and any required state or federal stormwater permits.

F. Greater Setback May Be Required.

The Board of Adjustment may require greater setbacks where site conditions, topography, facility design, cooling technology, water-use characteristics, or other site-specific factors indicate that additional distance is necessary to protect public health, safety, and welfare, to achieve compliance with Section 6 of this ordinance, or to prevent adverse impacts to groundwater, surface water, or hydrologically sensitive features.

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WATER Pollution Ordinance Language Johnson County Iowa

9. Water Use. Facilities must use a closed-loop cooling system for data center equipment

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WATER Pollution Ordinance Language LINN County Iowa

Water Study. A water study shall be submitted demonstrating that sufficient water resources are available to support the proposed use as described in Section 107-151 § (n)(1) below.

Water Use Agreement. The applicant shall submit a water use agreement to govern ongoing coordination between the applicant and the County regarding water use during operation of the facility as described in Section 107-151 § (n)(2) below.

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WATER Pollution Ordinance Language LINN County Iowa

Site and structure requirements, including:

Stormwater management plan;

Stormwater pollution prevention plan;

Erosion and sediment control plan;

All Data Center production equipment (computers, servers, etc.) shall comply with Building Code requirements. Said structure(s) shall be placed on a permanent foundation.

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WATER Pollution Ordinance Language LINN County Iowa

Water Supply and Sustainability Review. Approval for large-scale data center projects shall be conditioned on the applicant demonstrating there is sufficient reliable water supply to meet all projected water demands without undue adverse impacts on existing users, aquifers, or watersheds. To demonstrate this, the applicant must comply with the following requirements:

(1) As part of any application for rezoning, special use permit, or other discretionary land use approval for a data center, the applicant shall submit a Water Study. The purpose of this plan is to demonstrate, at a planning-level, that sufficient water resources are available to support the proposed use without causing undue adverse impacts to existing water users, groundwater resources, or surface water systems. The plan shall describe the proposed water source(s), anticipated ranges of water demand, assumptions regarding cooling technologies, efficiency measures, system reliability considerations, and general contingency approaches for water supply interruptions or emergencies. The plan shall be prepared by a qualified professional and shall contain sufficient information to allow the County, reviewing bodies, and the public to understand and evaluate the potential water impacts of the proposed use.

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WATER Pollution Ordinance Language LINN County Iowa

Prior to issuance of any building permit for a data center, the applicant shall enter into a Water Use Agreement with Linn County. The purpose of the Water Use Agreement is to govern ongoing coordination between the applicant and the County regarding water use during operation of the facility. The agreement shall address, at a minimum, water use monitoring, reporting frequency, data sharing protocols, and verification of compliance with applicable permits and approvals. The agreement may also include provisions addressing response procedures during periods of water supply constraint, drought, emergency conditions, or other circumstances in which water use reductions or operational adjustments may be necessary to protect public health, safety, or existing water users. The Water Use Agreement may include additional terms related to adaptive management, mitigation measures, and enforcement as determined appropriate by the County and Applicant. The Water Use Agreement shall also require the Applicant to demonstrate coordination with the Iowa Department of Natural Resources (IDNR) regarding applicable water use permits, interference mitigation procedures, monitoring obligations, and compliance procedures.

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D. Setbacks

Edge and Minor Data Centers (including Data Center Accessory Uses) shall be set back [1000] feet from the boundary of [RESIDENTIAL ZONING DISTRICT(S) INCLUDING AGRICTULTURAL AND CONSERVATION ZONES WITH A RESIDENCE] or the lot line of any property developed with a sensitive receptor.

Hyper and Major Data Centers (including Data Center Accessory Uses) shall be set back [2000] feet from the boundary of [RESIDENTIAL ZONING DISTRICT(S) INCLUDING AGRICTULTURAL AND CONSERVATION ZONES WITH A RESIDENCE] or the lot line of any property developed with a sensitive receptor.

Road rights-of-way – 1,000 feet from all adjoining properties and public road rights-of-way.

5

0260308_LCPC_Zoning_Ordinance_Amendment_1_of_2026_V2_1_Data_Centers

Parking lots - 50 feet from public road rights-of-way, and from all property lines.

Waterbodies – 500 feet to any body of water, perennial or intermittent stream or wetland.

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Water and Sewer

The use may utilize a closed-loop cooling system.

The use shall deploy technologies for water conservation including, not limited to, installing closed-loop or recirculation systems to reduce demands on the water supply.

If the use is served by a public water supply, the applicant shall submit documentation from the public authority certifying that the public authority will supply the water needed.

If the use is to rely upon non-public sources of water, the applicant shall provide a water feasibility study. The purpose of the study is to determine if there is an adequate supply of water for the proposed use and to estimate the impact of the use on all existing wells, groundwater, and surface waters in the vicinity. No Data Center shall be approved unless the water feasibility study demonstrates that the anticipated water supply yield is adequate for the project and that the proposed water withdrawals and discharges will not endanger or adversely affect the quantity or quality of groundwater supplies or surface waters in the vicinity. The water feasibility study shall include the following information at a minimum: ...

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Water and Sewer

The water feasibility study shall include the following information at a minimum:

The projected water demands of the Data Center;

The source of water to be used;

A description of how water will be used, including the amount or proportion of water to be used for each purpose (e.g. cooling, humidity control, fire suppression, and domestic usage);

The long-term safe yield of the water source;

A description of the amount or portion of water withdrawn that will be recycled or discharged and by what means;

A geologic map of the area with a radius of at least one mile from the site;

The location of all existing and proposed wells within one (1) mile 1,000 feet of the property boundary, with a notation of the capacity of all high yield wells, including residential and commercial wells not registered with the State of Pennsylvania;

The location of all surface waters, including perennial and intermittent streams, rivers, lakes, reservoirs, ponds, wetlands, springs, natural seeps, and estuaries, within one (1) mile 1,000 feet of the property boundary

A determination of the effects of the proposed water supply system on the quantity and quality of water in nearby wells, surface waters, and the groundwater table;

A statement of the qualifications and the signature(s) of the person(s) preparing the study Pag

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WATER Pollution Ordinance Language LUCERNE County PA

The applicant shall provide proof of review and approval from the Susquehanna River Basin Commission for projects proposing:

Water withdrawals of 100,000 gallons per day (gpd) or more over a 30-day average from any source or combination of sources within the Susquehanna River Basin; or

Any consumptive water use of 20,000 gpd or more over a 30-day average from any water source.

The applicant shall demonstrate that adequate means of wastewater disposal, including domestic wastewater and wastewater used for cooling or industrial purposes, have been provided and approved by the Sewage Enforcement Officer and/or the Pennsylvania Department of Environmental Protection.

The applicant shall provide for review by the Zoning Hearing Board, Planning Commission, Engineer, and/or other appropriate entity(ies) as applicable an Environmental Impact Statement, as outlined in Section 808, to disclose the potential environmental consequences of the proposed project. This shall include the creation and management of a Pollinator Protection Plan in accordance with the Pennsylvania Pollinator Protection Plan (P4) from the Pennsylvania Department of Agriculture and Penn State University

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Model Large-Load Data Center Ordinance

Public Education / Municipal Review Draft

Version 7.2

SECTION 9. Cooling, Water, Wastewater, and Process Chemicals

General standard.

Mandatory true closed-loop / non-evaporative cooling.

Prohibited cooling technologies.

No routine cooling-water withdrawal regardless of source.

Limited non-routine water uses.

No exemption for evaporative primary cooling.

Cooling Water Balance and Zero Routine Cooling-Water Demonstration.

Anti-evasion; substitute water-consuming thermal management. I. Metering and reporting.

Metering and reporting.

River basin commissions.

Water emergency curtailment.

Wastewater.

No cooling blowdown or unauthorized discharge.

Process chemicals and closed-loop coolant management.

Coolant replacement, flushing, and disposal.

Annual coolant and chemical certification.

Power-generation water use.

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WATER Pollution Ordinance Language Sierra Club

D. The purpose of this ordinance is NOT to prohibit data centers. The purpose is to allow appropriately sited data centers ONLY where the APPLICANT DEMONSTRATES, by substantial evidence, that the use and all associated infrastructure can SATISFY OBJECTIVE STANDARDS protecting public health, safety, welfare, environmental resources, water and sewer capacity, emergency services, neighboring land uses, and sensitive receptors.

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Closed-Loop Cooling System / Non-Evaporative Closed-Loop Cooling System means a cooling or heat-rejection system that recirculates a heat-transfer fluid in a sealed or materially sealed loop and does not rely on routine water withdrawal, evaporation, discharge, blowdown, or consumptive water use for primary IT cooling or facility heat rejection....

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Closed-Loop Coolant and Chemical Management Plan means a plan identifying each

heat-transfer fluid,

water-glycol mixture,

glycol product,

corrosion inhibitor,

biocide,

dielectric fluid,

cleaning/flushing agent,

treatment chemical,

WATER Pollution Ordinance Language Sierra Club

and related process chemical used in any sealed-loop cooling, liquid-cooling, immersion-cooling, power-generation, fire-suppression, battery, or maintenance system; • the maximum and typical on-site volumes;

the maximum and typical on-site volumes;

safety data sheets;

containment;

leak detection;

inspection;

replacement/flushing procedures;

spill response;

Model Large-Load Data Center Ordinance Public Education / Municipal Review Draft Version 7.2

Version 7.2

and authorized reuse, recycling, treatment, or disposal pathway

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Power Generation Water Use means water withdrawal, consumption, evaporation, fogging, wet compression, water or steam injection, boiler makeup, condenser cooling, HRSG makeup, blowdown, water treatment, process wastewater, or heat-rejection water use associated with On-Site Generation, Behind-the-Meter Generation, or a Fossil-Fueled Primary Generation Facility.

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WATER Pollution Ordinance Language Sierra Club

• Aggregated Water Demand

Load, generator capacity, water demand, wastewater discharge, cooling capacity, building area, equipment yards, and operational impacts shall be aggregated across a Unified Development

An applicant may not avoid this ordinance by phasing, subdivision, affiliated entities, separate tenants, separate meter arrangements, temporary generation, mobile units, or incremental applications.

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WATER Pollution Ordinance Language Sierra Club

Version 7.2

Cooling, Water, Wastewater, and Process Chemicals Plan meeting Section 9, including a

sealed water balance,

zero routine cooling-water demonstration,

non-cooling water-use summary,

wastewater-capacity review,

process-chemical inventory, and

metering/reporting plan.

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WATER Pollution Ordinance Language Sierra Club

Version 7.2

Water-Service Priority and DROUGHT CURTAILMENT DISCLOSURE. The application SHALL INCLUDE ALL water-service agreements, will-serve letters, capacity-reservation agreements, tariffs, private water-supply contracts, drought-contingency provisions, utility commitments, side letters, economic-development commitments, minimum-purchase obligations, take-or-pay provisions, reserved-capacity commitments, and related documents governing water service to the LLDC. The applicant shall identify whether any agreement provides firm, preferential, non-interruptable, reserved-capacity, take-or-pay, or priority water service during drought, water emergency, public-health emergency, fire-flow event, or system-capacity constraint.

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WATER Pollution Ordinance Language Sierra Club

Closed-loop coolant and chemical management.

The application shall include a Closed-Loop Coolant and Chemical Management Plan and SHALL PROHIBIT DISCHARGE of coolant, glycol mixture, dielectric fluid, corrosion inhibitor, biocide, flush water, cleaning water, treatment residual, or other process chemical to stormwater systems, groundwater, surface waters, or sanitary sewer except as expressly authorized by the applicable permitting authority and approved in the municipal record.

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WATER Pollution Ordinance Language Sierra Club

Spent catalyst, washwater, and waste management. Spent catalyst, catalyst washwater, reagent-contaminated absorbents, ammonia-contaminated materials, and related wastes shall be characterized, stored, transported, recycled, treated, or DISPOSED OF IN ACCORDANCE WITH APPLICABLE LAW. No spent catalyst or reagent-contaminated waste shall be disposed of on site or discharged to stormwater, sanitary sewer, groundwater, surface water, or land unless expressly approved under all applicable permits and municipal approvals.

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Model Large-Load Data Center Ordinance Public Education / Municipal Review Draft Version 7.2

A. General standard. Cooling systems and associated water supply, treatment, discharge, and chemical handling shall prevent contamination, avoid adverse impacts to groundwater, surface waters, neighboring wells, public water systems, municipal water/sewer infrastructure, drought resilience, and receiving waters, and comply with all applicable approvals. The standards in this Section are adopted as land-use, water-resource, sewer-capacity, drought-resilience, nuisance-prevention, infrastructure-impact, and environmental- protection requirements.

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WATER Pollution Ordinance Language Sierra Club

Version 7.2

D. Prohibited water-consuming turbine configurations. WATER-CONSUMING TURBINE CONFIGURATIONS ARE PROHIBITED for LLDC service. This includes, without limitation, CCGT/HRSG/steam-cycle equipment, cooling towers, evaporative condensers, wet-surface air coolers, condenser cooling, boiler or HRSG makeup water, steam-cycle blowdown, turbine inlet fogging, wet compression, evaporative inlet cooling, wet combustion control, water or steam injection for NOx control or output enhancement, and any routine process wastewater or blowdown associated with power generation or heat rejection.

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WATER Pollution Ordinance Language Sierra Club

Model Large-Load Data Center Ordinance

Public Education / Municipal Review Draft

Version 7.2

I. Metering and reporting. ALL WATER SOURCES SERVING THE LLDC SHALL BE METERED where practicable. The operator shall submit monthly water-use summaries for the first 24 months after operations and quarterly thereafter, identifying water use by category, including domestic, sanitation, fire/life-safety, sealed-loop maintenance, process, cleaning, landscaping, and any other non-cooling water use. Any use of water for cooling or heat rejection in violation of this Section shall constitute of this Section shall constitute a violation and Material Change requiring immediate notice and corrective action.

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K. Water emergency curtailment. During a declared municipal water supply, drought, or water quality emergency, the operator shall implement operational curtailment or other measures specified by the water provider or emergency authority to reduce non-essential water use and shall not initiate any water-consuming cooling or heat-rejection mode.

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WATER Pollution Ordinance Language Sierra Club

Model Large-Load Data Center Ordinance Public Education / Municipal Review Draft Version 7.2

L. Wastewater and Chapter 94. The LLDC shall not commence operations UNLESS THE APPLICANT DEMONSTRATES THAT THE RECEIVING SEWERAGE SYSTEM HAS SUFFICIENT PERMITTED, HYDRAULIC, AND ORGANIC CAPACITY TO

ACCEPT FULL-BUILDOUT non-cooling wastewater loads without causing or contributing to hydraulic overload, organic overload, permit violations, or Chapter 94 Wasteload Management noncompliance. Because cooling towers and evaporative cooling are prohibited, cooling tower blowdown or similar heat-rejection wastewater shall not be part of the approved wastewater load. The applicant shall provide capacity letters, projected peak and average non-cooling flows, pollutant characteristics, pretreatment needs, temperature, pH, TDS, biocides, corrosion inhibitors, and confirmation from the wastewater provider.

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WATER Pollution Ordinance Language Sierra Club

Version 7.2

N.1. Coolant replacement, flushing, and disposal. A TRUE CLOSED-LOOP SYSTEM SHALL NOT ROUTINELY DISCHARGE COOLANT. Any non-routine coolant replacement, flushing, filter changeout, reclamation, recycling, or disposal shall be performed only under an approved procedure using properly authorized vendors and manifests or equivalent documentation. No coolant, glycol mixture, dielectric fluid, inhibitor, biocide, flush water, cleaning water, treatment residual, or chemically contaminated water shall be discharged to stormwater systems, groundwater, surface waters, or sanitary sewer unless expressly authorized by all applicable permits, the sewer authority if applicable, and the municipal approval record.

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Version 7.2

N.2. Annual coolant and chemical certification. The operator shall annually certify coolant and process-chemical inventories, losses, leaks, spills, replacements, off-site shipments, recycling, treatment, and disposal. The certification shall include non-confidential disposal/recycling records and shall identify any event requiring notice to DEP, EPA, a river basin commission, a sewer authority, a water supplier, emergency responders, or the municipality.

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O. Power-generation water use. The zero routine cooling-water standard in this Section is not limited to IT cooling. Any Power Generation Water Use, including turbine inlet cooling, wet compression, fogging, wet combustion control, HRSG/boiler makeup, condenser cooling, cooling tower operation, steam-cycle blowdown, or power-generation process wastewater, is prohibited unless expressly allowed under Section 7B and approved as a Material Change after water, wastewater, air, noise, emergency-response, and solicitor review.

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P. Annual coolant and chemical certification. The operator shall ANNUALLY CERTIFY COOLANT AND PROCESS-CHEMICAL INVENTORIES, LOSSES, LEAKS, SPILLS, REPLACEMENTS, OFF-SITE SHIPMENTS, RECYCLING, TREATMENT, AND DISPOSAL. The certification shall include non-confidential disposal/recycling records and shall identify any event requiring notice to DEP, EPA, a river basin commission, a sewer authority, a water supplier, emergency responders, or the municipality.

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Steve Peake Data Center Accountability for the Citizens of Dubuque County

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WATER Pollution Ordinance Language Data Center Accountability for the Citizens of Dubuque County

Sec. 16-607. Additional Application Standards.

Wells. The application shall map every public, private, and shared well within one (1) mile of the site, with specific analysis of shared wells serving multiple households. Sec. 16-703 generally prohibits the use of wells for cooling of computing systems or energy production; this Section governs any other proposed water use. Where no on-site withdrawal of any kind is proposed, the Study shall document that condition and the prohibition on withdrawal shall be made a metered condition of the permit. The required testing, modeling, and drawdown demonstration are governed by the Comprehensive Hydrological Impact Study of Sec. 16-611.

Surface Waters. The application shall map all surface waters within two thousand five hundred (2,500) feet of the site.

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Sec. 16-703. Cooling Systems and Water.

Required Technology. All cooling systems, primary, secondary, and auxiliary, serving computing, electrical, power generation, or energy storage components shall be air-cooled, Closed-Loop non-evaporative, or immersion cooling systems. Open-loop, once-through, evaporative, adiabatic, hybrid, spray-assist, misting, and water-consumptive cooling are prohibited. No exception, seasonal use, or alternative-technology approval is available.

Water Sources. Groundwater and surface water shall not be used for cooling. No private well shall supply cooling fluid or cooling-related water, and no private well for such purpose shall be permitted on the site. Sanitary and potable supply shall not be used for cooling in any capacity. Reclaimed wastewater delivered by a dedicated, independent line may serve as makeup or charge water for a Closed-Loop system, but shall not authorize any evaporative equipment or method

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C. Public-Source Closed-Loop Plans.

Where a Closed-Loop system charged from a public source is proposed, the application shall include a detailed written plan — water source, all constituents added to the cooling fluid, handling and disposal of fluids, non-aqueous fluid disclosure including hazardous characteristics, fluid life and disposal, scheduled flushing and fluid-replacement intervals with per-event refill volumes, which count against the consumption ceiling of subsection (D), and spill prevention and containment sufficient that no release to soil, groundwater, or surface water is possible — sealed by a professional engineer, with efficiency assessment across the County's ambient range (minus 30 degrees F to 105 degrees F) and heat-plume characterization. The plan shall comply with all Iowa DNR water use and discharge requirements, with continuous usage monitoring and monthly reporting to the County. Any overage shall be reported within forty-eight (48) hours and corrected within one (1) month, or the use authorization terminates until corrective action is fully implemented.

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WATER Pollution Ordinance Language Data Center Accountability for the Citizens of Dubuque County

Consumption Ceiling. The permit shall state maximum annual and peak-day water consumption, which shall not exceed [5,000] gallons per day cumulative for all operations, including server cooling, building climate control, and site maintenance, unless the Board makes written findings supporting a different ceiling. Exceedance of any ceiling is a violation. Water for server and computing rack cooling is restricted under subsection (B); this ceiling governs all other water use and total cumulative facility consumption in any event.

Verification. Before operations commence, a licensed professional engineer shall verify by pressure testing or equivalent inspection that all Closed-Loop systems are leak-tight. Cooling system integrity shall be re-verified upon any Material Change to the cooling plant.

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WATER Pollution Ordinance Language Data Center Accountability for the Citizens of Dubuque County

Supplier Certification. Water and wastewater supplier certifications shall meet Sec. 16-606.

Waste Heat. Thermal discharge, venting, or exhaust shall not raise the ambient temperature at any Property Line above naturally occurring conditions, measured at four (4) feet above ground. A Thermal Impact Mitigation Plan shall accompany the application.

Reporting. Water use shall be metered and reported monthly to the County, broken out as minimum, average, and peak daily use and as potable versus non-potable supply, and posted on the Public Dashboard, together with an annual energy and water report via ENERGY STAR Portfolio Manager, including Power Usage Effectiveness (PUE) and Water Usage Effectiveness (WUE) metrics and Scope 1 and Scope 2 greenhouse gas emissions, including generator carbon dioxide, calculated per the EPA Greenhouse Gas Reporting Program methodology or equivalent.

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WATER Pollution Ordinance Language Data Center Accountability for the Citizens of Dubuque County

• I. Refrigerants.

All cooling and refrigeration systems shall use refrigerants with zero Ozone Depletion Potential and Global Warming Potential compliant with the EPA phasedown in effect at application; chlorofluorocarbons and halons are prohibited.

Any system containing fifteen (15) pounds or more of refrigerant shall be continuously monitored by automated leak detection; detected leaks shall be repaired within fourteen (14) days with follow-up verification; refrigerant purchase, disposal, and leak records shall be retained five (5) years and produced on request; and at decommissioning all refrigerants shall be recovered and recycled by EPA-certified technicians and equipment.

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J. Water Shortage Response. The water and wastewater management plan shall include a drought and water-shortage response plan providing that, upon any drought or water-shortage declaration by the State of Iowa, the Iowa Department of Natural Resources, the County, or the serving water supplier, or upon any supplier-imposed conservation measure, the facility shall curtail water use before, and to a greater degree than, any restriction imposed on residential, agricultural, or essential public uses, following a tiered schedule ending at zero non-sanitary withdrawal. Compliance with the consumption ceiling of subsection (D) does not excuse curtailment under this subsection

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Ordinance Language Data Center Accountability for the Citizens of Dubuque County

Sec. 16-704. Stormwater.

The site shall retain all stormwater associated with a three (3) inch daily rainfall on non-absorptive surfaces, in addition to all otherwise applicable County stormwater requirements, per a detailed Stormwater Pollution Prevention Plan filed with the application. Post-development peak stormwater release rates shall not exceed pre-development peak rates for the 2-year, 10-year, 50-year, and 100-year storm events. For runoff calculation under the Iowa Stormwater Management Manual, all compacted gravel switchyards, substation and transformer pads, battery storage foundations, and similar outdoor infrastructure shall be treated as one hundred percent (100%) impervious.

Within five (5) statute miles of the Dubuque Regional Airport, no open-water retention pond or other standing-water feature shall be constructed or maintained, and required retention shall be met by underground or dry systems; stormwater design shall avoid hazardous wildlife attractants per Article IX. Elsewhere, detention shall use dry basins designed to drain fully within forty-eight (48) hours.

There shall be no discharge of process water, cooling blowdown, or contact stormwater to surface water or groundwater except after treatment in full compliance with applicable permits.

Erosion, Sediment, and NPDES Compliance. All roadwork and site development shall comply with the applicant's National Pollutant Discharge Elimination System (NPDES) permit as required by the Iowa Department of Natural Resources and with the Dubuque County Erosion and Sediment Control and Stormwater Ordinance; the Stormwater Pollution Prevention Plan shall be filed with the County before any construction and kept current through construction.

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WATER Pollution: Recommended Inclusion

• Recommend Including WATER Pollution Prevention in Data Center Ordinance • Recommend Including WATER Pollution Prevention in County Ordinance for All Industries/Other

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WATER Pollution: Recommended Monitoring

WATER Study With Application

Stipulation of Water Use and Pollution Prevention Constraints

Continuous Monitoring

On-line WATER Pollution Dashboard on Dubuque County Website

Paid for by Data Center

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WATER Pollution: Recommended Sanctions for Non-Compliance

Shut Down of Facility Until Compliance Issues Addressed

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What is your greatest concern about the impact of water pollution on you/your family's health?