A poorly planned data center can be defeated by launching a low-cost yet credible citizen monitoring effort showing applicants, future tenants, and elected officials they will be held accountable for preventing excessive noise, air pollution, water waste, and other impacts to area residents. A comprehensive citizen monitoring effort can be a key component of an overall strategy to gain data center economic benefits without harm to those living, learning, or working nearby. Conversely, holding a well-planned data center accountable through citizen monitoring will help ensure unforeseen impacts are quickly corrected.

This webpage introduces inexpensive, reliable methods citizens can use to verify that a data center is not harming area residents by ensuring full compliance with best noise, air pollution and other impact prevention laws like those presented in the CEDS publication Key Data Center Zoning Ordinance Components. CEDS can help design a data center citizen monitoring program and win the adoption of impact prevention laws applying to both proposed and existing data centers. For further help establishing your data center citizen monitoring program and winning good laws, contact CEDS president Richard Klein at 410-654-3021 or Rklein@ceds.org.

Here are examples of the many low-cost, yet reliable methods citizens can use to monitor data centers to ensure those living nearby are safeguarded.

EXAMPLES OF WHAT DATA CENTER CITIZEN MONITORING CAN ACHIEVE

One of the earliest and most publicized instances of excessive data center noise occurred in Prince William County, Virginia and harmed Great Oaks residents. Shortly after a massive data center opened next to Great Oaks, residents began experiencing a very disturbing and persistent low-frequency hum from the data center. After County officials and the data center operator failed to correct the problem, Great Oaks residents began their own monitoring program which eventually led to the data center spending $50 million to reduce – though not fully eliminate – noise. It also led to Prince William County spending $2 million to research and propose a far more effective noise ordinance, though important safeguards were never fully adopted.

CEDS citizen monitoring surveys for even relatively simple, easy to enforce laws like construction site erosion and sediment control and stormwater pollution prevention indicate that only a fourth to half of sites fully comply. By publicizing the lack of compliance these surveys quickly doubled or tripled compliance. This is why citizen monitoring of data centers is essential to ensuring full compliance with all safeguards.

MONITORING DATA CENTERS FOR EXCESSIVE NOISE

The noise emitted by data center cooling equipment, backup generators, and other sources has made life miserable for nearby residents. Excessive noise has been a problem at 10% to 18% of data centers. Sensitive meters have detected data center noise up to two miles distant.

Relatively accurate, inexpensive, and easy-to-use noise meters are available such as the  Decibel X iPhone app. There are also hand-held meters costing less than $100. It is important that the meter measure both A- and C-weighted decibels (dBA and dBC). More expensive, professional meters that measure octave band frequencies start around $500 but may require training to use effectively. For most citizen monitoring needs the less expensive meters should suffice.

For further detail see the Noise section of the CEDS How to Protect Your Home from Data Center Impacts webpage.

MONITORING DATA CENTERS FOR EXCESSIVE AIR POLLUTION & HEALTH IMPACTS

The principal data center air pollution sources are onsite diesel- or gas-fired backup generators as well as remote power plants. The nitrogen oxides, particulates, and other air pollutants released from power sources located at a data center can affect the health of those living within a mile.

Backup Generators: You can monitor data center pollution emissions with meters costing less than $300 such as the PurpleAir particulate (PM_2.5) sensor. The Loudoun Climate Project uses these sensors to monitor airborne particulate matter  in the portion of Virginia that has more data centers than any other place in the world. Particulate levels are automatically uploaded to the PurpleAir map which shows the daily concentration and the health effects of that concentration (as shown below). There are also a number of hand-held devices that measure not only particulates but other data center air pollutants such as nitrogen oxides (NOx), volatile organic compounds (VOC), and carbon monoxide (CO). For further detail see the Air Quality, Neighborhood Health, Greenhouse Gases & Clean Energy section of the CEDS How to Protect Your Home from Data Center Impacts webpage.

Construction Phase: During data center construction, which can last 6- to 18-months, windborne soil particles can be another form of health-threatening air pollution. Federal law requires stabilizing (covering) exposed soil with straw mulch, grass, gravel, etc. once earthmoving has ceased for more than seven- to fourteen days. CEDS research shows that few construction sites comply with this law. If bulldozers and other earthmoving equipment are no longer present or have not operated on a site for more than a couple of weeks then all exposed soils must be covered. For further detail see the CEDS guidance materials at: https://ceds.org/publications/#construct.

MONITORING DATA CENTERS FOR WATER SUPPLY IMPACTS

A data center can consume a massive amount of water drawn from lakes, rivers, or underground aquifers. The water may be come directly from these sources or via a public (piped) water supply system. A large data center can use as much water as a town of 10,000 to 50,000 residents. Regardless of the source, it is essential to first insist upon a thorough assessment of how much water can be consumed by a data center without harming aquatic ecosystems or others relying on the same source. The assessment must be done by independent experts hired by the local government with funds provided by the data center applicant. The volume of water consumed will be minimized if a closed-cycle or direct-to-chip cooling is required. Following are examples of monitoring compliance with withdrawal limits for four water sources. Further detail is at the Water Supply Impacts section of the CEDS How to Protect Your Home from Data Center Impacts webpage.

Groundwater: If data center water is withdrawn from an underground aquifer then other users of the same groundwaters may be affected. There have been instances where a new major withdrawal lowered the water table sufficiently to cause nearby household wells tapping the same aquifer to go dry. By monitoring (observing) water levels in a nearby well(s) that draws water from the same aquifer you can determine if a data center withdrawal is excessive.

The U.S. Geological Survey (USGS) maintains a National Ground-Water Monitoring Network. If a USGS monitoring well is nearby and screened in the same aquifer tapped by the data center then it may suffice to check for suspicious changes in water level. If a USGS well is not nearby, see if your state or local government has monitoring wells in the area. If not then you and your neighbors may wish to look for abandoned wells that can be used for monitoring. As a last resort consider having a monitoring well(s) drilled on property you, your neighbors, or the local government control, at locations recommended by a qualified expert you select. Insist that the expert and drilling costs are covered by the applicant with funds paid to your local government.

Stream & River Withdrawal: Excessive withdrawals have caused streams and even rivers to run dry. An Instream Flow Analysis can determine how much water a data center can withdrawal without harming fish, wildlife, fire-fighting needs, public water supplies, and others consuming water from the same source. The Analysis will usually specify, in cubic feet per second, how much water must continue to flow in the stream to safeguard the aquatic ecosystem and other users.

The USGS maintains a National Water Dashboard with data from 11,000 stream and river gaging (monitoring) stations. If a gaging station is present downstream of the data center withdrawal point then it can show whether stream flow has dropped below the minimum established by the Instream Flow Analysis.

If a gaging station does not exist then there are relatively inexpensive methods volunteers can use to measure stream and smaller river volume below the withdraw point to determine if the minimum flow requirements are met.

For further detail see the CEDS Protecting Rivers, Lakes, & Wetlands from Land Development Impacts webpage.

Lake & Large Pond Withdrawal: As with ground and other surfaces waters, an assessment must be made by experts independent of the data center of how much water can be withdrawn from a lake or large pond before compromising other uses. As with streams and rivers lake water withdrawal limits may be based on fish, wildlife, and recreation needs, other lake withdraws as well as the amount of water that must flow from the lake to support downstream uses.

On most lakes there will be a limit on how far down the water surface can be drawn (lowered). Determining if a lake is reaching this critical level is usually easy to judge. For further detail see the CEDS Lake Quality: A More Effective Approach for Preserving & Enhancing Lake Quality webpage.

Public Water Supply Systems: If a data center will use water from the same pipe system that serves area homes, then keeping track of the amount of water flowing from the faucets of selected homes before and after a data center opens may show that nearby homes exhibit a greater reduction in flow compared to those farther away. Place a bucket beneath a fully opened kitchen faucet and record the time required to reach the one-or two-gallon mark. The measurements should be done regularly, say once a month, at a number of homes throughout the area. If homes nearest the data center exhibit a greater reduction in flow after it opens when compared to pre-opening data, then the data center may be having a greater impact than anticipated. The results of regular measurements should be summarized in updates to area residents, elected officials, the media, and data center owners-tenants.

More precise measurements may be available from a local fire department, many of which conduct periodic fire-flow tests to ensure public (piped) water supply systems have sufficient pressure to meet fire-suppression needs. If a data center is drawing water from a tested system then request the results. If water pressure has dropped since a data center opened, ask fire officials if data center withdrawals may be the cause and, if so, if the pressure drop may affect the protection of area residents from fires.

MONITORING DATA CENTERS FOR WATER QUALITY IMPACTS

A data center can impact the quality of surface or groundwaters due to:

• Wastewaters – bathroom, cooling waters, etc. – discharged directly into nearby waters or indirectly via treatment plants,
• Pollutants washed from data center rooftops, streets, parking lots, other impervious surfaces, and lawns by stormwater which should be trapped in highly effective treatment measures,

• A reduction of groundwater recharge by rain-snowmelt infiltration, caused by covering data center site soils with impervious surfaces. Recharge provides the high quality dry-weather inflow essential to healthy aquatic resources, or
• Reducing forest and other natural vegetative covers along wetlands, waterways and throughout a watershed.

For further detail see the Sensitive Wetlands, Streams & Lakes section of the CEDS How to Protect Your Home from Data Center Impacts webpage and the CEDS Protecting Rivers, Lakes, & Wetlands from Land Development Impacts webpage.

MAKING DATA CENTER REGULATORY INSPECTIONS-MONITORING MORE EFFECTIVE

While on the surface it may appear that local and state agencies have comprehensive programs to ensure compliance with noise and other safeguards, in far too many cases the reality is quite different. For example, data centers can emit noise at a frequency that is very disturbing but undetectable with the meters issued to most enforcement personnel. And even if inspectors have the right meters they may lack the specialized training to use the meters correctly. Finally, local officials must have the will to fully enforce noise laws at data centers which may be providing large, essential tax revenue; a possible conflict of interest.

CEDS citizen monitoring surveys for even relatively simple, easy to enforce laws like construction site erosion and sediment control and stormwater pollution prevention indicate that only a fourth to half of sites fully comply. By publicizing the lack of compliance these surveys have quickly doubled or tripled compliance. This is why citizen monitoring of data centers is essential to ensuring full compliance with all safeguards.

By putting elected officials on notice that citizen monitoring programs will be in place and findings will be publicized regularly and widely – especially before elections – it’s far more likely data centers will provide economic benefits without harm to area residents.

Site & Data Center Visits: As part of citizen monitoring effort insist that local officials allow you to occasionally accompany enforcement staff on site visits. Compare what staff find with what your monitoring shows. If results differ then ask why staff believe this to be the case, then verify staff explanations with independent experts.

Insist upon an opportunity to examine data center backup diesel generators. While data center owners-operators may oppose access to sensitive areas, generators are usually located away from servers and other proprietary equipment. One of the most effective options for minimizing data center noise and air pollution impacts is the use of generators meeting USEPA Tier-4 standards. If you won a requirement that only Tier-4 generators be used, then examine each data center backup engine for a plate like the examples below certifying Tier-4 compliance.

If you cannot gain access to generators then request the following items from your state air quality permitting agency:

1. The data center air discharge permit like the example at the following link: https://app.box.com/s/yse3ca12rgcsge2hqs206f4c7h6t11kk. The permit should show that Tier-4 generators are required or that engines with other Tier ratings were required to have add-ons that achieve Tier-4 emission standards such as:
   • Selective catalyst reduction (SCR) to control nitrogen oxide (NOx) emissions,
   • Diesel particulate filter (DPF) to control particulate matter (PM) emissions, and
   • Diesel oxidation catalyst (DOC) to control carbon monoxide (CO) and volatile organic compound (VOC) emissions.
2. The permit will limit the number of hours per year generators may operate during testing and emergencies. Request a copy of documentation showing that limits were not exceeded. Those living near a data center may be able to tell when generators are run by the noise and smoke emitted from the engines. Compare the actual duration of operation with permit limits and claims made by data center representatives and local officials.
3. Inspection reports and monitoring results.

For further detail see the Ensuring Accurate Impact Assessments & Long-Term Protection section of the CEDS How to Protect Your Home from Data Center Impacts webpage.

PUBLICIZING CITIZEN MONITORING DATA TO SAFEGUARD AREA RESIDENTS FROM DATA CENTER IMPACTS

Publicity is the key to using your monitoring data to safeguard area residents. While your data may not serve as evidence in court, it only need be sufficiently credible to convince the media, elected officials, and your neighbors that it gives a strong indication that a problem exists. The resulting public pressure should be enough to prompt elected officials to engage independent experts to verify your findings, though in more than a few cases corrective actions has been initiated without the need for further testing.

Design your monitoring effort to gather pre-construction, construction-phase, and post-construction data. Since this may mean a monitoring effort spanning years, it must be designed so it is easy for volunteers to perform. Automatic monitoring, like that with the PurpleAir particulate sensors mentioned above, is the best though not always possible.

Monitoring updates should be regular but infrequent such as once a month to every three months. The Loudoun Climate Project blog and newsletter can serve as a model for providing data center citizen monitoring updates. Of course, if you start detecting increases in noise, air pollution, or other data center impacts then an immediate alert (update) should be sent along with a demand for corrective action. For further suggestions contact CEDS president Richard Klein at 410-654-3021 or Rklein@ceds.org.