Public comment

Submit a comment on the draft standard.

Comment period: September 4 to November 3, 2026. Comments are read by the convener and, once seated, the Standards Advisory Committee. Every comment received is logged below with the commenter's organization, unless anonymity is requested, and a summary of how each was resolved is published with version 1.0.

How to comment

Email comments@computestewardship.com. Reference the section or item number (for example, E1 or C3). Say who you are and whether you are commenting for an organization. Redlines of the PDF are welcome. If you want your comment logged without your name, say so.

What we most want challenged

Section 10 of the draft lists seven open questions: the 85% hourly matching band, the 36-month additivity window, whether an energy reuse factor of 0.15 is reachable in the United States, the resident-majority composition of the advisory council, the 1% matched contribution level, tenant-level citation in colocation, and the 500 kW scope floor. Comments on those carry the most weight in this cycle.

Comment log

Every comment received is logged here. The first four entries are the convener's own, drawn from the public record before the draft was published, and are listed so that the source of each change is visible.

Date	Commenter	Section	Summary	Resolution
2026-09-05	Convener, citing Lily Gangas (Kapor Foundation) at the Brookings CTI webinar, February 17, 2026	Section 9; open question 8	The draft had no treatment of end of life. Gangas: "how do you dispose of data centers... the whole life cycle."	Adopted. Decommissioning and site restoration plan with financial assurance, and continuity of fund contributions through closure, added as a condition of certification at Provisional tier and above. Open question 8 asks whether it should be scored instead.
2026-09-05	Convener, citing Supervisor Mike Turner (Loudoun County) at the same webinar	E3	Electricity service agreements are proprietary and utilities now quote four to seven years to full power; a community cannot judge impact from a phase-one number.	Adopted. E3 now requires publication of the projected load ramp schedule to full build-out.
2026-09-05	Convener, citing Lily Gangas at the same webinar	W4, E3	Proposed facilities should disclose expected water and power use 90 days in advance.	Adopted. W4 and E3 now require public disclosure of projected water demand and peak power demand at least 90 days before the first local approval hearing.
2026-09-05	Convener, citing Nicol Turner Lee (Brookings) at the same webinar	Pillar Four	Digital access belongs in any community benefit agreement; the draft's Pillar Four did not address it.	Adopted. New item C7 (2 points): the needs assessment evaluates broadband availability and affordability, digital access becomes an eligible fund priority where a gap exists, and the fiber route is assessed for public middle-mile use. C1 reduced to 5 and C3 to 7 to hold the pillar at 25.
2026-09-05	Convener, responding to the three audience questions on enforcement at the same webinar (51:21 to 57:14)	Pillar Four, C4	Asked what enforcement of a community benefit agreement looks like, no panelist had a mechanism. The draft did not say how it related to executed agreements.	Adopted. Pillar Four now states that it assesses whether an agreement is being carried out, not how it was negotiated, and C4 requires quarterly reporting against every commitment in an executed agreement, with the agreement published. The scorecard is the enforcement mechanism: publication, annual re-audit, suspension for misstatement.
2026-09-05	Convener	Section 9	The decommissioning condition required fund continuity through closure but said nothing about the public record. A scorecard that disappears when a facility closes or changes hands is not a record.	Adopted. Every scorecard, fund statement, and assessment summary remains published after re-tiering, suspension, sale, or decommissioning, and is never removed at an operator's request. The record belongs to the host region.
2026-09-05	Convener, from a gap audit against the published record: the Brookings panel, the CURE webinar with the Better Data Center Project, the Kapor Foundation’s California siting analysis, the NAACP template, the AI Now policy toolkit, the Lancaster agreement, Yale Insights, and the Lincoln Institute	Structural: Sections 4 to 9	Eleven of twelve themes raised repeatedly across those sources had no coverage: siting against cumulative burden, tax abatement disclosure, fiscal impact, security behind community payments, proportionality of the contribution, electronic waste, emergency services, traffic, and workforce training. Separately, heat recovery held a quarter of the score while appearing almost nowhere in what host communities raise.	Adopted. Five pillars of 20 points: Water and Resource Efficiency, Additive Energy, Siting and Local Environment, Fiscal Accountability (new), and Verified Community Benefit. Heat recovery reduced from 25 points to 6 and folded into Pillar One; closed-loop cooling reduced from 8 to 5 as it approaches standard practice. Nine new items added. Open questions 11 to 14 put the new thresholds, the siting rule, and the heat recovery reduction out for comment.
2026-09-05	Convener, prompted by Supervisor Mike Turner (Loudoun County) at the Brookings webinar and by the Better Data Center Project's work on backup generation	Structural: Sections 4 to 9	The draft scored water, energy, heat, and money, and scored nothing a resident hears, breathes, or sees. Noise is reported as the single largest community complaint in the sector; the draft contained no mention of noise, lighting, setback, or generator emissions.	Adopted. The standard moves from four pillars of 25 points to five of 20, adding Pillar Four: Local Environment (night-time sound against pre-construction ambient with an absolute ceiling, independent monitoring, Tier 4 generators with capped hours and no demand-response use, dark-sky lighting, setbacks and screening). Verified Community Benefit becomes Pillar Five. Existing items were rescaled proportionally and no requirement was weakened. Local Environment carries a floor at every tier including Entry. New open question 10 asks whether the sound bands are right and whether that floor is correct.
2026-09-05	Convener, citing Sarah Friedman (Better Data Center Project) on the CURE webinar	C1, C3, Section 9, open question 10	Four points: unpaid community councils exclude the residents most affected; contributions written against the original build miss the three-to-seven-year equipment refresh; decommissioning assurance should be a bond proportional to project value; and a community benefit agreement typically includes a covenant by the signing groups not to challenge the approvals, which the draft did not acknowledge at all.	Adopted in part. C1 now requires stipends and a paid coordinator funded from the fund. C3 treats equipment refresh as a triggering event. Section 9 requires a bond proportional to capital value. On the covenant not to challenge, added as open question 10 rather than a scored item, because the Council does not negotiate agreements and should not imply it can dictate their terms; comment invited on whether it should be scored, and on how narrowly it should be defined.