Make the most out of this Data Center Moratorium

Make the most out of this Data Center Moratorium

Dear Hon. Michelle L. Phillips, Secretary to the Commission I am a New Yorker concerned that the AI data centers projected for development across the state will overwhelm our utilities, undermine environmental quality, adversely impact public health, and put ratepayers at risk for dramatically increased costs because of the infrastructure and extraordinary power demands of these facilities. While I am grateful for the current moratorium on data center construction, I am concerned that the narrow proposed scope of the GEIS will miss critical opportunities to avoid, minimize, and mitigate data center impacts, and I urge the Public Service Commission to broaden the GEIS scope to truly consider and avoid the worst impacts of this industry. The Draft Scoping Document fails to track the requirements of the Governor’s Executive Order by focusing narrowly on the “promulgation of interconnection processes and cost allocation standards” rather than “assess[ing] the potential environmental impacts of the construction and operation of data centers in the state,” including impacts on energy demand, water use, air quality, noise, and disadvantaged communities, as the Executive Order directs. The final scope must define the action to consider all aspects of the development, permitting, and authorization of data centers. To assist with this task, the PSC must formalize a role for DEC to play as an “involved agency” in the creation of the GEIS to ensure the most comprehensive review on critical issues like water quality, toxic exposures, environmental justice, habitat protection and air pollution. In addition, the draft scope must be expanded to include: - a more comprehensive exploration of alternatives - both technological advances that avoid impact and “no action” alternatives that set prohibitions to facilities and processes that present little societal value but insurmountable challenges to community or environmental health; - analysis of e-waste production from data centers which can be considerable and if mishandled can lead to contamination events with negative health impacts; - specific identification and analysis of polyfluoroalkyl substances (PFAS) and related “forever” chemicals that interface with the AI data center industry in a myriad of ways and present a significant threat to human health and the environment; - an affirmation that the PSC will actually review issues of anticipated climate change impacts, cultural and historical impacts, land use and landscape impacts, impacts to water resources, impacts to biodiversity, and impacts to public health. The current draft scope merely suggests it “may” undertake such analysis on these critical issues. In your development of this GEIS I am urging you to utilize the state’s time honored hierarchy to avoid, minimize and only then mitigate any environmental challenge presented by a development project. Please prioritize the health and safety of our communities before considering the interests of those that would consume great resources to manufacture questionable content and wealth for the very few. Thank you for your consideration of these comments.