Attachment A - Item 108 - Back-Up Memo.pdf

City of Phoenix — Formal (2025-07-02)

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To: 
From: 
City of Phoenix 
PLANNING AND DEVELOPMENT DEPARTMENT 
Alan Stephenson 
Deputy City Manager 
Joshua BednarelG 
Planning and Development Director 
Date: 
June 26 2025 
Subject: ITEM 108 ON THE JULY 2, 2025, FORMAL AGENDA - PUBLIC HEARING -
AMEND CITY CODE - ORDINANCE ADOPTION - DATA CENTERS - Z-TA-2-25-
y (ORDINANCE G-7396) - CITYWIDE 
Item 108, is a request to hold a public hearing on a proposed text amendment Z-TA-2-25-Y 
to amend the Phoenix Zoning Ordinance Chapter 2, Section 202 (Definitions) to add a 
definition for data centers; amend Chapter 5, Section 507 Tab A.I1.D (Guidelines for 
Design Review, City-Wide Design Review Guidelines, Specialized Uses) to modify the 
section title and add design standards for data centers; and amend Chapter 6, Section 647 
(Special Permit Uses), Section 647.A.2 to add data centers within the C-2 (Intermediate 
Commercial), C-3 (General Commercial), CP/GCP (Commerce Park/General Commerce 
Park), A-1 (Light Industrial), and A-2 (Industrial) zoning districts, with a Special Permit and 
performance standards. 
Fourteen Village Planning Committees have considered the request. Two VPCs 
recommended approval, per the staff recommendation; three VPCs recommended 
approval, per the staff recommendation, with direction; one VPC recommended approval, 
per the staff recommendation, with a modification; one VPC recommended approval, per 
the staff recommendation, with a modification and direction; three VPCs recommended 
denial; four VPCs recommended denial, with direction; and one VPC did not have quorum. 
The Planning Commission heard this item on June 5, 2025, and recommended approval, per 
the memo from the Planning and Development Department Deputy Director dated June 4, 
2025, by a vote of 9-0. 
The proposed regulatory framework in Z-TA-2-25 responds to the challenges data centers 
pose to the health and safety of Phoenix residents. The regulatory framework is also 
consistent with City Council adopted policy and initiatives regarding access to healthy food, 
health care services and heat response. Staff have compiled an overview of the health and 
safety risks data centers present along with the City Council policy and initiative intersections 
in a report. The report is attached to this memo as Exhibit A. 
Exhibit B attached to this memo is a copy of the proposed text amendment language as 
approved by the Planning Commission. 
ATTACHMENT A

1 
 
 
www.vanarsdelltd.com 
 
 
 
HEALTH AND SAFETY IMPACTS: 
DATA CENTERS  
2025 
Report prepared by the City of Phoenix Planning and Development Department  
Exhibit A

2 
 
Health and Safety Impacts: Data Centers 
 
This report provides additional information regarding GPA-2-25-Y and Z-TA-2-25. The report 
outlines health and safety concerns implicated by the evolution of data centers from small 
5,800 square-foot office-like buildings to 48-foot-tall industrial buildings on one hundred 
plus acre parcels with unprecedented energy demands and on-site power generation. The 
report was compiled with input from the Office of Environmental Programs and the Fire, 
Community and Economic Development and Information Technology departments.  
Growth of Phoenix, and of “Data Centers” 
Phoenix continues to be one of the fastest growing cities in the country. According to the U.S. 
Census Bureau, Phoenix added more than 16,000 residents to its population between July 
1, 2023, and July 2024 putting it in the top ten of growth for cities in the country.i  
Phoenix has seen tremendous amounts of investment with this growth in a variety of 
industries and sectors, including data centers. Based on a review of available data there are 
more than a dozen existing data centers within Phoenix’s boundaries and there are six data 
centers in the development review process, with the Planning and Development Department 
as of the writing of this memo.  
As noted in the staff report for Z-TA-2-25-Y, Phoenix does not define nor explicitly address 
data centers in the Phoenix General Plan and the Phoenix Zoning Ordinance. Historically, city 
staff considered some data centers as analogous to a general office, or to a 
telecommunications facility or “telecom hotel.” Some of these comparisons were 
documented by way of informal interpretations in an administrative process by city staff. 
However, the concept of a “data center” has changed dramatically over the years, and 
today’s data centers bear little resemblance to those that were built twenty, ten, or even five 
years ago.  
The activities carried out within today’s data centers have also shifted greatly in the last few 
years; as described below, an AI data center is a fundamentally different land use when 
compared to a traditional office or to the old concept of a “telecom hotel,” and it features 
unique equipment and energy use patterns that create unique threats to public health and 
safety beyond the borders of the data center property.ii   
Data Centers: Change in Scale, Intensity + Health and Safety Impacts  
Many of the data centers in Phoenix have been built within the last decade. Within that time 
frame, they have increased dramatically in scale.iii Fifteen or twenty years ago, a “data 
center” might fill a few thousand feet of an existing office building, without requiring 
significant modifications to that building.  But one of the more recent data centers built near 
40th Street and McDowell Road is more than 80 acres in size and requires the development 
of a new electrical substation. This change in the scale and intense use of electrical power 
has necessitated a new definition of “data center” to differentiate it from uses which can no 
longer be considered analogous and has created the need for new zoning standards that 
account for the impact this use has on surrounding properties.  Given their size, energy 
demands, and potential desire for onsite energy generation, today’s data centers are not 
analogous to office uses or telecommunication facilities.

3 
 
Health and Safety Impacts: Data Centers 
 
Related to their intense operations, recent incidents across the United States and the world 
have highlighted the health and safety challenges data centers pose to residents including, 
but not limited to, strains on energy and water resources, threats to the electrical grids 
existing users rely upon, increased emissions created by heavy energy consumption, noise, 
heat, and strain on public safety resources. In addition, data centers pose unique risks to 
first responders due to their size, sensitivity, and high concentration of batteries and 
electrical equipment.  
Data Center Energy Demand: Significant Risks to the Electrical Grid 
Projections provided by the electricity utility providers Arizona Public Service (APS) and Salt 
River Project (SRP) show that energy demand in the industrial sector of their service areas is 
anticipated to be more than 90% for data center development (Figure 1). As Phoenix and the 
region continue to grow, ensuring that there are sufficient energy resources to support a 
reliable electrical grid, especially during the hot summer months, is one of the greatest 
challenges facing utility companies and municipalities.  
 
Figure 1: Projected Industrial Energy Demand 
In a 2024 updated report by the Lawrence Berkeley National Laboratory, funded by the 
Department of Energy at the request of Congress, entitled United States Data Center Energy 
Usage Report (2016), historical data center electrical consumption was reviewed back to 
2014, and future demand was projected out to 2028.  Of note, the report found that by 2018 
data centers would account for 1.9% of all electricity consumption in the United States.  The 
report found that electrical consumption grew at an accelerated rate, with annual growth at 
7% from 2014 to 2018, increasing to 18% between 2018 and 2023 and projected to further 
increase 13%-27% between 2023 and 2028.  That translates into data centers consuming 
6.7% to 12% of all the electricity in the United States.ivv

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Health and Safety Impacts: Data Centers 
 
The projected growth in Data Centers represents an unprecedented surge in demand for 
electricity. The Department of Energy has predicted that data center electricity use will 
double or triple by 2028vi. According to the Arizona Corporation Commission (ACC), Data 
Center electricity use has increased 67% over the last year and that figure does not include 
the 170-175 megawatts of product under construction as of the end of 2024.vii  For context, 
according to the ACC, 100 megawatts are enough to power several thousand homes in a day, 
and Arizona data centers rank 4th in the nation for electricity they consume when compared 
with data centers in other cities.viii  
APS recently indicated that it expects its peak load to jump 40% by 2031 (5 years from now). 
In late 2024, an APS official explained that the utility “has about 10 GW in pending 
interconnection requests from data centers, but the utility cannot commit to serving them 
because it would put existing customers at risk of having poor reliability.”ixx  
APS provided an update on these figures in response to GPA-2-25-Y and Z-TA-2-25, and as of 
the date of this report it “is planning to serve 3.3GWs of power to new data center projects. 
In addition, we have a queue of requests from data centers for approximately 15GWsxi.  As 
APS suggests in its update, the scope of pending data center projects calls for “early-stage 
coordination with City departments – such as Planning and Development, Water Services, 
and Economic Development” to understand the demand these projects will have on the grid 
and “to ensure that new growth proceeds in a manner that is both technically viable and 
aligned with broader infrastructure capabilities.” Meanwhile, SRP is currently reviewing 
requests for over 17 GW of load from approximately 60 pending data center projectsxii. 
The ACC recently opened a new matter to study the likely impacts of data centers on existing 
utility customers. In opening the matter, its Chairman explained: “Our utilities are currently 
having a challenging time meeting the generational challenges of existing customers. We 
need to explore potential solutions for developing behind-the-meter solutions to meet large 
customer needs and growth that don't jeopardize the integrity of our grid.”xiii xiv 
Data Center Demands on Available Land  
This elevated demand for energy coincides with a corresponding increase in demand for 
land for data centers. If data centers are treated like regular offices, properties zoned for 
commercial, commerce park and industrial land uses can be developed into data centers 
with very few restrictions. Commercial, commerce park and industrially zoned land equate 
to approximately 20% of Phoenix’s land area (108 square miles / 530 square miles). Of these 
108 square miles, only 3% of it (17 square miles) is vacant and ready for development such 
as employment, health care, grocery stores or services.  
As a fast-growing city, Phoenix has increasing needs for a diversity of jobs, health related 
services and access to healthy food. Continued unfettered build-out of data centers within 
Phoenix hinders the private sector market’s ability to provide these resources to city 
residents.

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Health and Safety Impacts: Data Centers 
 
Health and Heat in Phoenix (Importance of Grid Stability to the Health and Safety of 
Existing Residents and Land Users) 
In response to increases in summertime temperatures and the number of days Phoenix 
experiences temperatures more than 110 degrees; the City of Phoenix established the Office 
of Heat Response and Mitigation in 2021. The Office coordinates programs and policies to 
help lower urban temperatures and protect public health. It also tracks trends, collects data, 
and collaborates with other governments and organizations to share ideas and solutions for 
dealing with heat including the development of the Phoenix Heat Response Plan.  
The 2025 Heat Response Plan documents the increased heat challenges and public health 
risks Phoenix is attempting to address including:  
• The 2024 Heat Season in Phoenix set many records with respect to the severity and 
duration of extreme heat conditions. The most notable records from 2024 included 
new all-time highs for the number of days with temperatures reaching 110°F (70) and 
the number of nights with temperatures failing to drop below 90°F (39).  
• The 2024 season also set a record for the number of consecutive days with 
temperatures reaching at least 100°F (113). Average high and low temperatures for 
June, September, and October all set historical records; average low temperatures in 
August were also record-setting. 
• Heat-related deaths have increased considerably in Maricopa County since 2014. 
Particularly large year-over-year increases were evident from 2015 to 2016 (+83%), 
2019 to 2020 (+62%), and 2021 to 2022 (+25%). Another large increase is evident from 
2022 to 2023, with an increase of more than 47% to the record high of 625 cases in 
Maricopa County that was recorded that year. 
 
Within this context of a growing desert city attempting to respond to the health challenges 
that heat poses for its residents, the added strain that an influx of data centers will place on 
the energy grid warrants a more strategic approach regarding where they are developed and 
what steps should be taken to mitigate their impact on existing users.  
Phoenix is not unique in grappling with energy demand challenges posed by data centers, 
but a stable electric grid is especially important here because it powers air conditioning, 
which is essential to human life for much of the year and which places its own heavy burden 
on the grid. The risk to Phoenix and all cities is highlighted by research done by the North 
American Electric Reliability Corporation (NERC), the federal regulator for grid reliability. The 
NERC founded a taskforce to study electrical grid disruptions caused by data centers and 
crypto miners. The NERC released a report in December of 2024 that found that the risk of 
power outages will only grow as new data centers come online. Nearly all the United States 
will face higher risks of energy shortfalls over the next 5 to 10 years, according to the reportxv. 
The data center threat to grid stability and to existing power users is not simply a matter of 
total demand. In addition to their unparalleled energy appetite, data centers further stress 
the grid with inconsistent flow patterns and short bursts of high usage.xvi This phenomenon 
is especially pronounced with data centers that support AI, which produce unpredictable

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Health and Safety Impacts: Data Centers 
 
energy spikes and which “are being built faster than grid upgrades can keep up.”
xviii
xvii These 
spikes can lead to immediate grid failures, but they can also cause “bad harmonics” that 
degrade the lifespan of connected electrical equipment including home appliances, can 
lead to sparks and home fires, and can eventually lead to grid blackouts as effects 
compound and escalate.
  These effects have been observed in other jurisdictions, 
including Loudoun County, Virginia, where bad harmonic readings have been reported to 
reach four times the national average.xix These are direct negative impacts on existing users 
of all types, so expectations of large-scale intermittent power use must be identified and 
addressed on the front end in order to mitigate major adverse consequences on public 
health and safety.  
 
Onsite Power Generation and Emissions  
One of the data center industry’s responses to the power demand their facilities are placing 
on the electrical grid is to try to go it alone by establishing onsite power generation 
independent of the grid. This response has been seen in Arizona, where utilities, utility 
regulators, and the state legislature have all publicly called for “on-site” or “behind-the-
meter” generation to help ease the impact data centers have on our electric grid. ACC 
Chairman Thompson recently stated that “we need to explore potential solutions for 
developing behind-the-meter solutions to meet large customer needs and growth that don't 
jeopardize the integrity of our grid.” 
 
The utilization of onsite power generation poses numerous challenges including potentially 
unregulated and independent power generation without state or federal oversight; 
establishing power generating plants in neighborhoods, with all the related impacts to 
residents; environmental impacts from air and water emissions, depending how the energy 
is generated; the unknown impacts to an existing electrical grid in the event onsite power 
generation fails and data centers revert to their backup power all at once. As an example, 
power companies in Virginia had to scramble during the summer of 2024 when 60 of the 
area’s 200 data centers out of Washington D.C. came off the grid and started using backup 
power all at once, nearly setting off a series of rolling blackouts.xx 
 
In 2024, the company xAI opened a data center in southwest Memphis, Tennessee. The 
facility had negotiated an agreement with the public utility, Memphis Light, Gas and Water, 
to draw 150 megawatts of power from the local grid. This was the amount the utility had 
determined it could safely provide without affecting the availability and reliability of power 
for existing users – but it was not enough to fully power the data center, which has applied 
for an additional 150 megawatts. While its request for additional grid power was pending, xAI 
is reported to have installed 35 gas-powered generators on its property. These generators 
ignited significant concern and opposition from the surrounding community and from 
environmental and health advocacy groups, which cited to the potential human health and 
air-quality consequences of what a local lawmaker described as a “gas plant in the middle 
of a neighborhood.”xxi

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Health and Safety Impacts: Data Centers 
 
This experience highlights the need to understand where a data center will receive its power. 
A data center that produces its own power – either permanently or while a local utility is 
ramping up its generating capacity – presents different health and safety considerations than 
a data center that gets all its power from a public utility, and large-scale on-site power 
production may not be compatible with existing residential or other uses. Even when a data 
center can be fully powered by the local utility, it may need a new substation or the 
installation of new high-capacity transmission lines, and the impact of such infrastructure 
on existing nearby uses should be understood. 
The power source for backup and onsite power generation of many data centers is a diesel 
generator.xxii As noted by the Washington Department of Ecology in analyzing data centers’ 
use of diesel power generation: 
• Diesel exhaust is a toxic air pollutant, containing fine particles that can cause health 
problems for people who are exposed frequently and at high enough levels.  These 
tiny particles are too small to be filtered out of the air by the nose and upper 
respiratory system.  The particles go deep into the lungs, where they can cause 
damage and chemical changes. 
• Nitrogen dioxide (NO2) is another toxic air pollutant that can cause breathing 
problems even when you're exposed for a short time, from 30 minutes to 24 hours.  
Nitrogen dioxide can make breathing harder for people who already have lung 
problems, such as asthma.  It also adds to acid rain and smogxxiii. 
Nuclear energy has been identified as a dedicated power source for data centersxxiv.  
Amazon, Microsoft, Google and Meta are investing in nuclear power to provide power for 
their data center needs. These may include “small modular reactors” which are small, cost-
effective sources when compared to the traditionally large (and very expensive) nuclear 
power plants most people are familiar withxxv.  The Georgetown Environmental Law Review 
Online (February 27, 2025) reports that the Virginia legislature adopted a statutory scheme 
to incentivize nuclear power to meet growing energy needs of artificial intelligence (AI) from 
a zero-carbon, climate friendly, renewable source.xxvi  
Onsite nuclear power generation has gained enough support in Arizona that a bill to support 
it was approved by the state legislature in its current session. HB 2774, which received 
support from all three of the State’s largest electric utilities but was ultimately vetoed by the 
Governor, encouraged “small modular nuclear reactors” to “collocate” with data centers by 
exempting collocated reactors from the requirement to obtain an environmental 
compatibility certificate. The specter of small, loosely regulated nuclear power plants 
popping up everywhere to meet the accelerating demand for energy is further proof that the 
location of a new data center must be carefully considered, and this consideration must 
account for the data center’s expected power sources. As state authorities encourage data 
centers to include major power generation facilities, it becomes increasingly important to 
carefully consider the locations of such data centers.

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Health and Safety Impacts: Data Centers 
 
Data Center Water Usage  
While much of the attention regarding the resource demands of data centers has focused on 
electricity, water resources are an area that still must be factored into their evaluation. Data 
center water usage has improved in recent years due to changes in the cooling methodology 
used, but recent studies suggest that water savings come at the cost of increased electricity 
use and point to the industry continuing to need larger amounts of waterxxvii. For desert cities 
and water providers like Phoenix, the ability to properly evaluate and regulate data center 
water usage is paramount for the City’s survival.  
Data Centers and Fire Safety  
Data centers represent a new and challenging service area for firefighters. According to the 
International Association of Fire Fighters the growing presence of data centers requires 
specialized training, lots of planning and close cooperation with on-site security and 
engineering teams at these new sitesxxviii.  
The City of Phoenix Fire Department has noted the following challenges with data centers: 
• Fires in data centers can produce vast quantities of dense, corrosive smoke, which 
contains known carcinogens. Visibility may become nearly impossible, and when 
combined with unfamiliar building configurations, the prospect of disorientation is 
clear. Often, even a small fire isolated by the building's fire protection systems is a 
high-risk and long-duration incident for responding firefighters. 
• Two physical hazards in large data centers, which are generally not present to the 
same intensity as other occupancies, are large lithium-ion batteries and electrical 
power. 
• Lithium-ion batteries contain volatile electrolytes that can release flammable gases 
when exposed to high temperatures or physical damage. 
• If a battery generates more heat than it can dissipate for any reason, it can lead to 
rapid and uncontrolled heat releases, resulting in a fire (thermal runaway). In many 
instances, fire sprinkler systems prevent fire spread, but cannot extinguish. 
• Accidental battery overcharging can lead to fires. 
• Batteries can be ejected from their casing during a fire, potentially spreading the fire 
or causing secondary ignitions. 
• Burning batteries release toxic chemicals into the air.  
• Due to the large amounts of energy required, electrical distribution and fires involving 
electrical components are another possibility. Firefighters must be familiar with the 
power disconnect procedures and the vast electrical hazards of large data centers. 
• Fire incidents in large data centers can necessitate using large volumes of water to 
bring the fire under control, and contaminated runoff is an additional concern. This 
runoff may contaminate surrounding soil and could get into the city’s storm drain 
system and impact land miles away from the actual location. 
•  Fires involving lithium-ion batteries also release toxic heavy metal particulates, 
requiring specialized decontamination of firefighter personal protective equipment.

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Health and Safety Impacts: Data Centers 
 
 
Advanced review of proposed data centers would provide an opportunity for the Phoenix Fire 
Department to provide critical insight into the proposed location, design and operation of 
future data centers. That review will include an assessment of existing resources available 
to serve the proposed data center location. Fire resources are not evenly distributed 
throughout the City, and in some cases the City may need to invest in new infrastructure, 
equipment, or resources to ensure its ability to serve new data center developments, or to 
serve new data center developments without leaving existing users unprotected. This 
analysis will be especially important when large data centers replace farmland, or other 
much lower intensity uses (and such replacements have become increasingly common).  
The Phoenix Fire Department works with other emergent technologies to address fire safety 
concerns and to ensure safety for building occupants, the surrounding public, and 
responding fire crews.  As a contribution to this report, the Department wrote that it “is fully 
committed to understanding new technologies and the associated evolution of our fire 
protection efforts (i.e., fire suppression, prevention, and public education). We are a 
recognized industry leader in this space and a couple examples include lithium-ion batteries 
and energy storage systems, large warehouses, semiconductors, photovoltaics, electric, 
hybrid vehicles, etc..” The Department shared several examples of its specialized 
preparation for fires caused by other specialized land uses; those examples were consulted 
for this report, and several can be accessed in the references section. 
 
Fire Department review will also ensure compliance with the Phoenix Fire Code and industry 
best practices and will allow the Fire Department to learn about and prepare for the specific 
energy generation and storage equipment that will be present in a new data center. Energy 
storage technologies continue to rapidly evolve, and that makes this level of review critical 
to ensure that fire crews have equipment or techniques required based on the design and 
chemistry of such equipment. Without the opportunity to prepare for these new risks, the 
chance of a fire ignited by batteries or other electrical equipment spreading beyond a data 
center’s walls to harm those on nearby properties will be greatly increased. 
 
Data Center Security and Public Safety  
According to a recent analysis by the Information Technology Department, data centers are 
high-value investments and sometimes high-value targets, which may attract threats from 
foreign actors who seek to disrupt data centers for espionage or sabotage, or to access them 
for sabotage, disruption, or to exfiltrate valuable information.  Considering the size and cost 
of today’s data centers, the high profile of many data center owners, and the vast quantities 
of data stored within a single data center, this risk assessment should not come as a 
surprise.  The sophistication and frequency of these attacks, including from foreign 
locations, has increased.  As more data centers come online in the region, a complex 
challenge emerges that requires federal partnerships, strict resource management, and 
increased regional costs in cyber resilience and protection to ensure community safety and 
sustainability. Phoenix has already seen significant incidents targeting major industrial

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Health and Safety Impacts: Data Centers 
 
facilities, and future data centers storing highly valuable commercial information, or 
information related to national defense and security, may face even greater risks. The 
location of this kind of sensitive data center should be carefully considered to protect 
existing users and to ensure that adequate public safety resources are available in the 
relevant area.  
Access to Healthcare Services  
As one of the largest and fastest growing cities in the country the City of Phoenix has made 
providing residents with access to life-saving health care services one of its highest 
priorities. To that end, the City recently partnered with Arizona State University and the 
Arizona Board of Regents to establish a new medical school in downtown Phoenix to be 
opened in 2028.  
While there is excitement about the new medical school and the progress it will position 
Phoenix and the state to make, there are active areas of need in the health care sector in 
Phoenix. Some areas in Phoenix are considered a Health Professional Shortage Area (HPSA). 
A HPSA is a geographic area, population, or facility that has a substantial shortage of 
primary, dental, or mental health care providers designated by the Health Resources & 
Services Administration. For example, in Phoenix’s Laveen Village, there are 12 HPSA areas 
and in the South Mountain Village there are 24 HPSA areas. In addition, the Laveen and South 
Mountain villages do not have a Level 1 Trauma Center as defined by the Arizona Department 
of Health Services. Laveen and South Mountain are home to some of the largest areas where 
data centers could concentrate, preventing other development that could serve the 
surrounding community. Without an updated zoning framework, it will be nearly impossible 
to ensure that there will be any available land for a hospital or other medical services in these 
villages.  
Access to Healthy Food  
The Laveen and South Mountain villages also highlight challenges Phoenix faces in ensuring 
its residents have access to healthy food. In 2020 the Phoenix City Council adopted the 2025 
Food Action Plan to establish goals, policies and strategies to achieve a robust and healthy 
food system for Phoenix residents.   
The Food Action Plan analyzes the challenges Phoenix faces in achieving its envisioned food 
system.  According to the report, there are 55 food deserts in Maricopa County, and there are 
43 food deserts in Phoenix that amount to nearly half of Phoenix’s populated area. The Plan 
identifies the South Mountain, Laveen and Maryvale villages in Phoenix as areas most 
impacted by food deserts.  
Like the challenges in ensuring there is enough land area to provide the necessary health 
services to residents, Phoenix has a decreasing amount of available land for grocery stores. 
Preserving opportunities for access to healthy food, especially in areas that have been 
identified as food deserts, is critical for protecting the health of Phoenix residents. Allowing 
data centers to uncontrollably fill in and concentrate in these areas would run counter to the 
Phoenix’s Food Action Plan and frustrate plans to address food deserts.

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Health and Safety Impacts: Data Centers 
 
Data Center Noise Pollution  
One common detrimental health and safety consequence of data centers, which has been 
discussed during the public hearing process for Z-TA-2-25, has been noise. While there has 
been some debate regarding the minimum standards and methodology the city should 
employ, there has been little pushback on the notion that data centers do generate 
significant noise with significant impacts to neighboring properties.  
Data centers contribute to noise pollution due to the equipment inside making noise as it 
operates.xxix Noise around areas of data centers can reach up to 92 dB(A) for sites with 
greater densities of equipment, and up to 96 dB(A) inside.xxx The National Institute for 
Occupational Safety and Health (NIOSH) threshold for requiring hearing protection is 85 
dB(A) over an eight-hour period. As a result, people working in data centers and people 
residing in neighborhoods around them may be impacted by noise pollution.  
Constant humming and buzzing noises in nearby neighborhoods may have adverse health 
impacts including headache, stress, and sleep disturbancexxxi. Poor quality sleep and stress 
can also contribute to cognitive impairment and cardiovascular risks.  
With more information regarding noise generated by data centers becoming available, 
providing a regulatory framework that ensures that they are not located near residents will 
help protect the health and well-being of Phoenix residents.  
Regulatory Framework: Not a Ban 
The City does not have any plan or desire to enact a ban on data centers, and many data 
center projects may be warmly welcomed. However, a Special Permit requirement, like the 
requirement applicable to a self-storage warehouse in the city’s commercial zoning districts, 
would be a vehicle to help contain or mitigate the health and safety impact data centers have 
on nearby users. The Phoenix City Council has approved dozens of Special Permits for self-
storage and car dealerships in the last 10 years and may well approve a similar number of 
new data centers once health and safety challenges have been adequately addressed.  
The Special Permit Process: Response to Years of Council-Adopted Policy + A 
Collaborative Framework for the Future  
The policy and regulatory framework proposed in GPA-2-25-Y and Z-TA-2-25 position Phoenix 
to employ a holistic approach to the development of today’s “data centers,” which bear so 
little resemblance to the land uses that once used that same name. This new policy and 
regulatory framework are focused on protecting public health and safety from threats that 
easily cross the boundaries of a data center property, including fire, power disruption, and 
heat, noise, air, and wastewater pollution, and they respond to several existing City Council 
adopted policies including the Food Action Plan and Phoenix Heat Response Plan. The 
Special Permit process provides opportunities for city staff to evaluate proposed data center 
facilities and ensure that the location, design, site and operational features take into 
consideration the health and safety needs of the community. The requirements for 
agreements with electric utility providers will help the City understand the level of on-site

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Health and Safety Impacts: Data Centers 
 
generation, high-voltage transmission, or other infrastructure that is being approved, and to 
evaluate the likely impact of such infrastructure on the health and safety of existing nearby 
users.  
The Special Permit process will also allow the City to assess the adequacy of public safety 
resources near the data center, to assess the likely impact of the data center’s operation on 
those resources, and to determine whether additional resources will need to be developed 
or deployed. The Special Permit provides an opportunity for landowners, data center 
developers, city staff, neighbors and the Phoenix City Council to collaborate and ensure that 
new investments in data centers are strategically located within the city limits, and serve the 
best interests of the City, neighbors, and the data center developer. 
 
 
i https://www.census.gov/newsroom/press-releases/2025/vintage-2024-popest.html 
ii https://www.forbes.com/sites/rrapier/2025/03/26/how-ai-data-centers-are-reshaping-americas-electric-
grid/ 
iii See Report by the International Energy Administration (https://iea.blob.core.windows.net/assets/40a4db21-
2225-42f0-8a07-addcc2ea86b3/EnergyandAI.pdf): “Data centres – at least at the scale seen today – are 
relatively new actors in the energy system at the global level, and data collection and reporting on their 
electricity consumption remain limited.” 
iv https://escholarship.org/uc/item/32d6m0d1#page=50 
v https://www.eesi.org/articles/view/data-center-energy-needs-are-upending-power-grids-and-threatening-the-
climate (see section “Data Centers as a Paradigm Shift in the Electricity Sector) 
vi https://www.energy.gov/articles/doe-releases-new-report-evaluating-increase-electricity-demand-data-
centers 
vii https://ktar.com/arizona-business/acc-protect-payers-energy/5693869/ 
viii https://ktar.com/arizona-business/acc-protect-payers-energy/5693869/  
ix https://www.utilitydive.com/news/data-center-grid-reliability-residential-cost-aps-load-growth/732480/ 
x ACC Chairman Kevin Thompson recently noted “it took Arizona Public Service about a century to build a grid 
that meets the 8,400 megawatts demand it has now,” and that the utility will have to “double or triple their 
current grid capacity in a very short time to meet anticipated demand.” (https://ktar.com/arizona-
business/acc-protect-payers-energy/5693869/)  
xi APS Letter dated June 25, 2025 (attachment A) 
xii SRP Letter dated June June 26, 2025 (Attachment B) 
xiii ACC Chairman Kevin Thompson, April 10, 2025 statement upon opening “In the Matter of the Commission’s 
Inquiry and Review of the Existing Rate Classifications and other Potential Issues relating to Data Centers” 
(Docket No. E-00000A-25-0069). 
xiv This closely tracks a recent statement by Virginia State Corporation Chair Jehmal Hudson, who has been 
quoted stating: “When it comes to adding transmission and generation capacity, we’re trying to make a 
determination: how can we fulfill those needs to data centers, but also keep the lights on in the 
commonwealth?” (https://www.utilitydive.com/news/data-center-grid-reliability-residential-cost-aps-load-
growth/732480/) 
xv https://www.reuters.com/technology/big-techs-data-center-boom-poses-new-risk-us-grid-operators-2025-03-
19/#:~:text=%22What%20it%20tells%20us%20is,U.S.%20Federal%20Energy%20Regulatory%20Commission. 
xvi https://www.rcrwireless.com/20250417/fundamentals/ai-infra-energy-spikes 
xvii https://carboncredits.com/ais-energy-hunger-is-straining-americas-power-grids-and-your-home-appliances/; 
the impacts of AI are so significant that one researcher describes AI as “a big hammer” on the grid 
(https://www.datacenterdynamics.com/en/news/ai-data-centers-causing-distortions-in-us-power-grid-
bloomberg/) 
xviiihttps://www.datacenterdynamics.com/en/news/ai-data-centers-causing-distortions-in-us-power-grid-
bloomberg/; and https://carboncredits.com/ais-energy-hunger-is-straining-americas-power-grids-and-your-
home-appliances/

13 
 
Health and Safety Impacts: Data Centers 
 
 
xix https://www.datacenterdynamics.com/en/news/ai-data-centers-causing-distortions-in-us-power-grid-
bloomberg/ 
xx https://www.reuters.com/technology/big-techs-data-center-boom-poses-new-risk-us-grid-operators-2025-03-
19/ 
xxi https://amp.cnn.com/cnn/2025/05/19/climate/xai-musk-memphis-turbines-pollution 
xxii https://www.microgridknowledge.com/distributed-energy/article/11427459/why-do-data-center-operators-
choose-diesel-backup-over-cleaner-microgrids 
xxiii https://ecology.wa.gov/air-climate/air-quality/data-
centers#:~:text=Air%20pollution%20from%20data%20centers,can%20be%20built%20or%20expanded. 
xxiv 
https://www.eia.gov/todayinenergy/detail.php?id=63304#:~:text=Although%20historically%20costly%20to%2
0build,us%20about%20data%20center%20demand? 
xxv https://www.youtube.com/watch?v=58zHJL1dKtw  
xxvi Going Nuclear: Virginia’s Answer to the Intensive Energy Needs of Artificial Intelligence Data Center, 
Georgetown Environmental Law Review Online, February 27, 2025, Sarah Bosworth.   
xxvii https://www.bloomberg.com/graphics/2025-ai-impacts-data-centers-water-data/; see also 
https://www.sciencedirect.com/science/article/abs/pii/S0921344922000428?fr=RR-
2&ref=pdf_download&rr=94fff2af6fb1341c (describing the “trade-off between water and energy consumption” in 
data center design, by analyzing two Phoenix data centers served by SRP and identifying unique challenges 
presented by our “hot-dry climate.”  
xxviii https://www.iaff.org/news/data-centers-are-booming-and-fire-fighters-must-adapt-to-new-challenges/ 
xxix https://www.datacenterknowledge.com/sustainability/why-data-centers-are-loud-and-how-to-quiet-them-
down 
xxx https://www.sensear.com/blog/data-centers-arent-loud-right 
xxxi https://www.techtarget.com/searchdatacenter/tip/Understanding-the-impact-of-data-center-noise-pollution 
 
 
 Fire Department References: 
 
• 
Data-Driven Fire Operations - Firefighting - Fire Engineering 
• 
Lithium-Ion Batteries, Fire Investigations, and Keeping Pace with Emerging Technologies - 
BESS 
• 
The Impact of Solar Energy on Firefighting 
• 
FPRF_FireFitherSafety.pdf 
• 
EVTrainingEmergencyResponders.pdf 
 
 
Attachment A: Letter from APS dated June 25, 2025 
Attachment B: Letter from SRP dated June 26, 2025

14 
 
Health and Safety Impacts: Data Centers 
 
 
 
 
Attachment A: June 25, 205 letter from APS

15 
 
Health and Safety Impacts: Data Centers 
 
 
 
Attachment B: June 26, 205 letter from SRP

1 
Ordinance G- 
EXHIBIT B 
 
THIS IS A DRAFT COPY ONLY AND IS NOT AN OFFICIAL COPY OF THE FINAL, 
ADOPTED ORDINANCE 
 
 
ORDINANCE G- 
 
AN ORDINANCE AMENDING PORTIONS OF THE CODE OF THE CITY OF PHOENIX, 
ARIZONA, PART II, CHAPTER 41, THE ZONING ORDINANCE OF THE CITY OF 
PHOENIX BY AMENDING CHAPTER 2, SECTION 202 (DEFINITIONS) TO ADD A 
DEFINITION FOR DATA CENTERS; AMENDING CHAPTER 5, SECTION 507 TAB 
A.II.D (GUIDELINES FOR DESIGN REVIEW, CITY-WIDE DESIGN REVIEW 
GUIDELINES, SPECIALIZED USES) TO MODIFY THE SECTION TITLE AND ADD 
DESIGN STANDARDS FOR DATA CENTERS; AND AMENDING CHAPTER 6, 
SECTION 647 (SPECIAL PERMIT USES), SECTION 647.A.2 TO ADD DATA 
CENTERS WITHIN THE C-2 (INTERMEDIATE COMMERCIAL), C-3 (GENERAL 
COMMERCIAL), CP/GCP (COMMERCE PARK/GENERAL COMMERCE PARK), A-1 
(LIGHT INDUSTRIAL), AND A-2 (INDUSTRIAL) ZONING DISTRICTS, WITH A 
SPECIAL PERMIT AND PERFORMANCE STANDARDS. 
 
WHEREAS, the City of Phoenix (the “City”) is in the top 10 of fastest growing cities in the 
country, adding over 16,000 residents between July 1, 2023, and July 1, 2024; and 
 
WHEREAS, while managing this population growth, the City is seeing ever-increasing 
interest in data centers; and  
 
WHEREAS, today’s data centers are typically very large and intense uses, with some 
data centers being more than 90 acres in size and often require a new electrical 
substation or other significant new infrastructure; and 
 
WHEREAS, the activities carried out within today’s data centers have also shifted greatly 
in the last few years; and AI data centers are fundamentally different land uses when 
compared to an office or the outdated concept of a “telecom hotel.” Today’s data centers, 
and AI data centers in particular, feature unique equipment and energy use patterns that 
create unique threats to public health and safety beyond the borders of their properties; 
and 
 
WHEREAS, the proliferation of data centers within certain areas of the City may result in 
adverse impacts on local neighborhoods and other existing uses; and  
 
WHEREAS, there is convincing documented evidence that data centers pose risks to 
public health, and safety, including, but not limited to, potential negative impacts to the 
availability and reliability of power for neighboring properties because of significant, and

2 
Ordinance G- 
sometimes erratic, data center power consumption, potential air quality degradation and 
adverse noise impacts from onsite power generation, increased fire danger and response 
challenges, and potential adverse effects from typical operational noise, all of which 
extend beyond the boundaries of a data center property; and 
 
WHEREAS, because of the potential public health and safety impacts, land use 
considerations for data centers require individualized analysis; and 
 
WHEREAS, the City Council desires to avoid outright bans on data centers in most zoning 
districts and prefers to utilize the special permit process to ensure data centers comply 
with reasonable land use standards designed to address public health and safety 
concerns and to minimize negative secondary effects to the neighborhoods, businesses 
and residents around data centers, while still providing for opportunities for data centers 
at various locations within the City; and 
 
WHEREAS, when evaluating the negative secondary effects of data centers, the City is 
permitted to consider the impacts on health and safety that have been experienced in 
other urban areas; and 
 
WHEREAS, the City has compiled substantial data from other urban areas relating to 
negative secondary effects of data centers on surrounding neighborhoods, along with the 
findings and research previously conducted by its staff and consultants, in a report entitled 
“Health and Safety Impacts: Data Centers 2025” (the “Health and Safety Report”), which 
has been provided to and reviewed by the City Council, and is the primary impetus for its 
adoption of this ordinance; and 
 
WHEREAS, the City Council has determined this ordinance is necessary to address the 
health and safety challenges associated with data centers, including (i) risks to the public 
health and safety in the communities in which they are located, (ii) unique firefighting 
challenges, (iii) adverse environmental impacts to air, land, and water, (iv) extensive 
water usage, (v) noise pollution, (vi) significant energy demand, (vii) land use challenges, 
including a loss of land for jobs and housing, inactive frontages along public streets, and 
(viii) conflicts with the City’s approach of maximizing transportation investments with 
walkable communities.  
 
NOW THEREFORE, BE IT ORDAINED BY THE COUNCIL OF THE CITY OF 
PHOENIX, as follows: 
 
 
SECTION 1: Purpose. 
 
It is the purpose of this ordinance to (i) provide a process to review, monitor, and regulate 
data centers to ensure that the negative secondary effects of data centers do not 
adversely impact the health and safety of the residents of the City, and (ii) establish 
reasonable and uniform regulations to prevent and mitigate such adverse impacts 
(existing and potential) to residents, neighborhoods, and the City as a whole.  This

3 
Ordinance G- 
ordinance is not intended to ban data centers in most zoning districts, nor is it intended 
to discourage location of data centers in the City of Phoenix.    
 
The special permit regulatory framework employs a holistic approach to data center 
development and provides opportunities for City staff to evaluate the health and safety 
needs of the community and to ensure that the health and safety consequences 
associated with the location, design, site and operational features are taken into 
consideration.  In addition to the traditional site-related considerations, the City has 
determined it is necessary to require evidence of agreements with electric utility providers 
to ensure the local community will not be negatively impacted or imperiled by demands 
on the power infrastructure created by the data center, or by on-site power generating 
facilities that are incompatible with the health and safety of the existing residents. The 
special permit provides an opportunity for landowners, data center developers, City staff, 
neighbors and the Phoenix City Council to collaborate and ensure that new investments 
in data centers are strategically located in appropriate areas of the City and serve the 
best interests of the City, the neighbors, and the data center developer. 
 
SECTION 2: Findings. 
 
Studies, news articles, research articles, industry publications, relevant data, input from 
experts and consultants, and the review of the operations and impact of data center sites 
in other locations including, but not limited to, Phoenix, Mesa, Los Angeles, Memphis, 
Houston, Lincoln, Nebraska, Boston, Ogden, Utah, Seattle, Virginia, and overseas 
locations including South Korea, Belgium, Indonesia, Strasbourg, Milan, Belfast, and 
Madrid were gathered and reviewed.  The results have been summarized, with links to 
the source data, in the Health and Safety Report.  Upon review of the Health and Safety 
Report, and the source materials as deemed necessary, the City Council make the 
following findings: 
 
1. Increase in Size, Scale, Number and Power Usage. Phoenix is a desirable location 
for data centers due to its favorable climate.  Within the last decade, data centers have 
increased dramatically in scale, becoming intense users of land and local resources. 
This change in the scale and intense use of electrical power has necessitated a new 
definition of “data center” to differentiate it from uses that can no longer be considered 
analogous and has created the need for new zoning standards that account for the 
impacts data centers have on surrounding properties.  Related to their intense 
operations, recent incidents across the United States and the world have highlighted 
the health and safety challenges data centers pose to residents including, but not 
limited to, strains on energy and water resources, threats to the electrical grids existing 
users rely upon, increased emissions created by heavy energy consumption, noise, 
heat, and on-site generating facilities and strain on public safety resources. In addition, 
data centers pose unique risks to first responders due to their size, sensitivity, and 
high concentration of batteries and electrical equipment. 
 
a) Significant Power consumption.  Arizona Public Service (“APS”) and Salt River 
Project (“SRP”) anticipate that more than 90% of the energy demand in the

4 
Ordinance G- 
industrial sector of their service areas is related to data center development.  The 
projected growth in data centers represents an unprecedented surge in demand 
for electricity. The Department of Energy has predicted that data center electricity 
use will double or triple by 2028.  The special permit process, and in particular the 
requirement for the City Council to fully understand how power will be provided to 
meet the data center needs, is designed to ensure that the data center is proposed 
for a location with appropriate infrastructure, that an appropriate plan has been 
developed to construct that infrastructure, and that gap-bridging on-site 
infrastructure will not endanger existing nearby users.   
   
b) Potential to Destabilize Local Power Grid.  As Phoenix and the region continue to 
grow, ensuring that there are sufficient energy resources to support a reliable 
electrical grid, especially during the hot summer months, is one of the greatest 
challenges facing utility companies and municipalities. The risk to Phoenix is 
highlighted by research done by the North American Electric Reliability Corporation 
(“NERC”), the federal regulator for grid reliability. The NERC founded a taskforce 
to study electrical grid disruptions caused by data centers and crypto miners. The 
NERC released a report in December of 2024 that found that the risk of power 
outages will only grow as new data centers come online. Nearly all the United 
States will face higher risks of energy shortfalls over the next 5 to 10 years, 
according to the report.  Understanding a data center’s power usage, needs, and 
plans for providing that power, is an essential part of the special permit process, 
which is necessary to ensure that the introduction of a data center to an area does 
not imperil critical power reliability for nearby residents and businesses.  
 
The data center threat to grid stability and to existing power users is not simply a 
matter of total demand. In addition to their unparalleled energy appetite, data 
centers further stress the grid with inconsistent flow patterns and short bursts of 
high usage. These consequences are especially pronounced with data centers that 
support AI, which produce unpredictable energy spikes. These spikes can lead to 
immediate grid failures, but they can also cause “bad harmonics” that degrade the 
lifespan of connected electrical equipment including home appliances, can lead to 
sparks and home fires, and can eventually lead to grid blackouts as effects 
compound and escalate.  These effects have been observed in many places, 
including Loudoun County, Virginia, where bad harmonic readings have been 
reported to reach four times the average rate. These are direct negative impacts 
on existing users of all types, so expectations of large-scale intermittent power use 
should be addressed on the front end to mitigate major consequences on public 
health and safety.  
 
c) Onsite Power Generation.  SRP and APS are anticipating unprecedented 
additional demand for power related to data centers.  APS expects its peak load 
to jump 40% by 2031. APS officials have recently explained that the utility has 
more pending interconnection requests from data centers than it can fulfill without 
putting existing customers at risk of having poor reliability, and recent proceedings 
before the Arizona Corporation Commission have revealed support for developing

5 
Ordinance G- 
“behind the meter solutions” for data center power.  The lack of power from the 
electrical grid will place additional pressure on data centers to produce their power 
on-site.  During the 2025 legislative session, the Arizona legislature approved HB 
2774 (vetoed by the Governor but supported by the State’s three largest utilities), 
which incentivized small nuclear reactors that collocate with large industrial users 
by eliminating the requirements for collocated reactors to receive environmental 
compatibility certificates.  As detailed in the Health and Safety Report, in Memphis, 
Tennessee, a large data center utilized 35 gas-powered generators for on-site 
power generation in response to a lack of available power from the local power 
company. HB 2774 and the examples from other jurisdictions highlight the need 
for the City Council to ensure that the methods of power generation are closely 
evaluated (through the special permit process) to ensure the health and safety of 
neighboring residents and businesses are not adversely impacted.   
   
2. Limited available land employment generators; health care; and grocery stores. Of the 
land zoned commercial, commerce park and industrially zoned, only 3% of it is vacant 
and ready for development such as employment, health care, grocery stores or 
services.  Phoenix has increasing needs for a diversity of jobs, health related services 
and access to healthy food. Continued unfettered build-out of data centers within the 
City hinder the private sector market’s ability to provide these resources to Phoenix 
residents Phoenix has Health Professional Shortage Areas (“HPSA”), which are 
geographic areas that have a substantial shortage of primary, dental, or mental health 
care providers and food deserts.  In Phoenix’s Laveen Village there are 12 HPSA 
areas and in the South Mountain Village there are 24 HPSA areas.  
 
There are food deserts in Phoenix.  The City of Phoenix has adopted a 2025 Food 
Action Plan which analyzes the challenges residents face in achieving a healthy and 
robust food system.  Data centers contribute to the decreasing amount of land area 
available to provide the necessary health services to residents, including grocery 
stores. Preserving and opportunities for access to healthy food, especially in areas 
that have been identified as food deserts, is critical in protecting the health of Phoenix 
residents.  The special permit process allows the City Council to evaluate the impact 
of a proposed data center on health services for an area. 
 
3. Water usage.  While Data center water usage has improved in recent years due to 
changes in the cooling methodology used, these technologies tend to require larger 
amounts of power and recent studies point to the industry continuing to need larger 
amounts of water.  Additionally, for desert cities and water providers like Phoenix, the 
ability to properly evaluate and regulate data center water usage is paramount for the 
City’s survival. 
 
4. Fire Safety.  Data centers represent a new and challenging service area for 
firefighters. According to the International Association of Fire Fighters the growing 
presence of data centers requires specialized training, considerable planning, and 
close cooperation with on-site security and engineering teams at these new sites.  As 
detailed in the Public Safety Report, data centers have components that are typically

6 
Ordinance G- 
not present at the same scale and intensity in other occupancies of a similar size. The 
proposed special permit process for data centers will provide an opportunity for the 
Phoenix Fire Department to provide critical insight into the proposed location, design 
and operation of future data centers. That review will include an assessment of 
existing resources available to serve the proposed data center location. Fire resources 
are not evenly distributed throughout the City, and in some cases the City may need 
to invest in new infrastructure, equipment, or resources to ensure its ability to serve 
new data center developments, or to serve new data center developments without 
leaving existing residents and businesses unprotected. This analysis will be especially 
important when large data centers replace farmland or other much lower intensity 
uses. 
 
Fire Department review will also ensure compliance with the Phoenix Fire Code and 
industry best practices, and will allow the Fire Department to learn about and prepare 
for the specific energy generation and storage equipment that will be present on-site. 
Energy storage technologies continue to rapidly evolve, and that makes this level of 
review critical to ensure that fire crews have equipment or techniques required based 
on the design and chemistry of such equipment. Without advance knowledge, the 
chance of a fire sparked by large batteries or other electrical equipment spreading 
beyond a data center’s walls to harm those on nearby property will be greatly 
increased. 
  
5. Noise.  Noise around areas of data centers can reach up to 92 dB(A) for sites with 
greater densities of equipment, and up to 96 dB(A) inside. The National Institute for 
Occupational Safety and Health (NIOSH) threshold for requiring hearing protection is 
85 dB(A) over an eight-hour period.  These constant humming and buzzing noises 
may have adverse health impacts in nearby neighborhoods including headache, 
stress, and sleep disturbance. Poor quality sleep and stress can also contribute to 
cognitive impairment and cardiovascular risks.  The special permit process will allow 
the City to evaluate potential noise impacts to the surrounding areas to ensure that 
neighboring residents and businesses are not negatively impacted by unreasonable 
noise from the introduction of a data center to the area. 
 
6. Holistic Review of Health and Safety. In addition to the key concerns enumerated 
here, other jurisdictions have experienced other health and safety challenges 
including heat, noise, air, and stormwater pollution. Furthermore, as the quantity, 
value, and sensitivity of the data stored in today’s data centers continues to increase, 
these facilities become increasingly sensitive and generate security issues that can 
affect nearby users and the sufficiency of public safety resources. Given the rapid 
pace of evolution in data center size, equipment, power usage, and activities, a holistic 
review of new data center projects is required to ensure that they are located and 
designed with consideration for the many well-documented, and therefore predictable, 
consequences to the health and safety of existing residents and land users.  
 
 
SECTION 3:  The Code of the City of Phoenix, Chapter 2, Section 202 (Definitions) 
to hereby amended to add a definition for “Data Centers” to read as follows:

7 
Ordinance G- 
*** 
Section 202. Definitions. 
*** 
DATA CENTER: A FACILITY USED PRIMARILY FOR DATA SERVICES, INCLUDING
THE STORAGE, PROCESSING, MANAGEMENT, AND TRANSMISSION OF DIGITAL 
DATA. A FACILITY SHALL NOT BE CONSIDERED A DATA CENTER WHEN IT DOES
NOT EXCEED 10% OF THE GROSS FLOOR AREA OF ALL ON-SITE BUILDINGS; IS
USED TO SERVE THE ENTERPRISE FUNCTIONS OF THE ON-SITE PROPERTY
OWNER; AND IS NOT USED TO LEASE DATA SERVICES TO THIRD PARTIES. 
*** 
 
SECTION 4:  The Code of the City of Phoenix, Chapter 5, Section 507, Tab A.II.D 
(Guidelines for Design Review, City-Wide Design Review Guidelines, Specialized Uses), is 
hereby amended to modify the section title and add design standards for data centers, and 
to read as follows:  
Section 507 Tab A. Guidelines for design review. 
*** 
II. 
CITY-WIDE DESIGN REVIEW GUIDELINES. The design review guidelines indicate 
specific standards of implementation and are categorized as Requirements (R),
Presumptions (P), or Considerations (C). INDICATED WITH THE MARKERS (R), 
(R*), (P), (T), AND (C) SHALL BE APPLIED AND ENFORCED IN THE SAME 
MANNER AS INDICATED IN SECTION 507. ITEMS NOT INDICATED WITH AN
(R), (R*), (P), (T), AND (C) SHALL BE TREATED AS (R). 
*** 
 
D. 
Specialized Uses. 
*** 
 
5. 
DATA CENTERS.

8 
Ordinance G- 
 
 
5.1. 
SETBACKS.  ALL MECHANICAL EQUIPMENT, INCLUDING
BUT NOT LIMITED TO ELECTRICAL TRANSFORMERS
AND GENERATORS, SHALL BE SET BACK A MINIMUM OF 
150 
FEET 
FROM 
ABUTTING 
RIGHT-OF-WAY 
OR
RESIDENTIALLY ZONED PROPERTY; IN ADDITION TO 
THE FOLLOWING: (R*) 
 
 
5.1.1. THE EQUIPMENT MUST BE FULLY SCREENED BY 
A BUILDING THAT IS VISUALLY INTEGRATED WITH 
THE DESIGN OF THE OVERALL DEVELOPMENT; 
OR 
 
 
5.1.2 THE EQUIPMENT MUST BE FULLY SCREENED BY 
A 
DECORATIVE 
SCREEN 
WALL 
HAVING 
VARIATIONS IN COLORS, MATERIALS, PATTERNS, 
TEXTURES, AND/OR AN ART INSTALLATION SUCH 
AS A MURAL. 
 
 
RATIONALE: 
GROUND 
EQUIPMENT 
SHOULD 
BE
ENCLOSED AND SET BACK TO PROVIDE VISUAL 
SCREENING AND REDUCE NOISE LEVELS. 
 
 
5.2. 
LANDSCAPE SETBACK. A MINIMUM 30-FOOT WIDE
PERIMETER 
LANDSCAPE 
SETBACK 
SHALL 
BE 
PROVIDED, SUBJECT TO THE FOLLOWING: 
 
 
 
5.2.1. TWO STAGGERED ROWS OF LARGE CANOPY 
SHADE TREES PLANTED 20 FEET ON CENTER OR 
IN EQUIVALENT GROUPING SHALL BE PROVIDED, 
AS 
APPROVED 
BY 
THE 
PDD 
LANDSCAPE
ARCHITECT. (T) 
 
 
 
5.2.2 FIVE 5-GALLON SHRUBS PER TREE SHALL BE 
PROVIDED, AT A MINIMUM. (T) 
 
 
 
5.2.3 GROUNDCOVERS 
SHALL 
BE 
PROVIDED 
TO
SUPPLEMENT THE TREES AND SHRUBS SO THAT 
A MINIMUM 75% LIVE COVERAGE IS ATTAINED. (T) 
 
 
 
RATIONALE: AN ENHANCED LANDSCAPE SETBACK 
WITH A DENSE NUMBER OF TREES AND SHRUBS HELPS
TO MITIGATE NEGATIVE VISUAL IMPACTS.

9 
Ordinance G- 
 
 
5.3. 
ARCHITECTURE. 
 
 
 
5.3.1. BUILDING FACADES THAT EXCEED 100 FEET
SHOULD 
CONTAIN 
ARCHITECTURAL
EMBELLISHMENTS AND DETAILING SUCH AS 
TEXTURAL CHANGES, PILASTERS, OFFSETS, 
RECESSES, 
WINDOW 
FENESTRATION 
(INCLUDING FAUX WINDOWS), SHADOW BOXES,
AND OVERHEAD/CANOPIES. (P) 
 
 
5.3.2. ALL SIDES OF A BUILDING/STRUCTURE SHOULD
PROVIDE AN ENHANCED DESIGN INCLUDING A 
VARIATION IN COLORS, MATERIALS, PATTERNS, 
TEXTURES, HEIGHT, WINDOWS (INCLUDING FAUX
WINDOWS), 
ARTICULATION, 
AND/OR 
ART
INSTALLATIONS. (P) 
 
 
5.3.3. EACH MAIN ENTRANCE SHOULD INCLUDE A
FEATURE THAT DIFFERENTIATES IT FROM THE
REMAINDER OF THE BUILDING FACADE BY A 
CHANGE IN BUILDING MATERIAL, PATTERN, 
TEXTURE, COLOR, AND/OR ACCENT MATERIAL,
AND THAT PROJECTS OR IS RECESSED FROM 
THE ADJOINING BUILDING PLANE. (P) 
 
 
5.3.4. ARCHITECTURAL DESIGN SHOULD TAKE INTO
ACCOUNT THE SOLAR CONSEQUENCES OF 
BUILDING HEIGHT, BULK, AND AREA. (C) 
 
 
RATIONALE: 
DATA 
CENTER 
BUILDINGS 
SHOULD
INCLUDE 
ENHANCED 
ARCHITECTURAL 
DESIGN
FEATURES IN ORDER TO PROVIDE VISUAL INTEREST,
TO BREAK UP THE MASS OF THE BUILDING/STRUCTURE 
AND TO PROVIDE AN ENHANCED DESIGN INTERFACE
WHERE VISIBLE FROM A RIGHT-OF-WAY AND/OR
RESIDENTIALLY ZONED PROPERTY. 
 
 
5.4. 
STREETSCAPE. FOR EACH STREET FRONTAGE, A
MINIMUM 
6-FOOT-WIDE 
DETACHED 
SIDEWALK
SEPARATED FROM THE CURB BY A MINIMUM 8-FOOT-
WIDE 
LANDSCAPE 
STRIP, 
SUBJECT 
TO 
THE 
FOLLOWING:

10 
Ordinance G- 
 
 
5.4.1. SINGLE-TRUNK, LARGE CANOPY SHADE TREES, 
PLANTED 
20 
FEET 
ON 
CENTER 
OR 
IN
EQUIVALENT GROUPINGS, SHALL BE PROVIDED 
ON BOTH SIDES OF THE SIDEWALK AND PROVIDE
A MINIMUM OF 75% SHADE. (T) 
 
 
5.4.2 A 
MIXTURE 
OF 
SHRUBS, 
ACCENTS, 
AND
VEGETATIVE GROUNDCOVERS WITH A MAXIMUM 
MATURE HEIGHT OF TWO FEET SHALL BE
DISTRIBUTED THROUGHOUT THE LANDSCAPE
AREAS TO ACHIEVE A MINIMUM OF 75% LIVE 
COVERAGE. (T) 
 
 
5.4.3 ALL NEW OR RELOCATED ELECTRIC LINES 12 KV 
AND SMALLER, COMMUNICATIONS AND CABLE
TELEVISION AND ALL ON PREMISE WIRING SHALL 
BE 
PLACED 
UNDERGROUND 
IN 
ALL
DEVELOPMENTS WHERE VISIBLE FROM STREETS 
OR 
ADJOINING 
PROPERTIES, 
UNLESS 
OTHERWISE APPROVED THROUGH A TECHNICAL
APPEAL. (T) 
 
 
RATIONALE: AN ENHANCED STREETSCAPE HELPS TO 
SOFTEN THE EDGE OF THE DEVELOPMENT OF A 
LARGER NON-RESIDENTIAL USE. 
 
 
5.5. 
SHADE.  
 
 
5.5.1. ALL ON-SITE PEDESTRIAN PATHWAYS SHOULD 
BE SHADED A MINIMUM OF 75% BY A STRUCTURE, 
LANDSCAPING, OR A COMBINATION OF THE 
TWO. (P) 
 
 
5.5.2 DEDICATED MULTI-USE TRAILS ADJACENT TO
THE SITE SHOULD BE SHADED A MINIMUM OF 50%
AT TREE MATURITY. (P) 
 
 
RATIONALE: 
ENHANCED 
PEDESTRIAN 
COMFORT
SHOULD BE PRIORITIZED ADJACENT TO AND WITHIN
DATA CENTER DEVELOPMENTS ACROSS THE CITY. 
***

11 
Ordinance G- 
SECTION 5:  The Code of the City of Phoenix, Chapter 6, Section 647 (Special
Permit Uses), Section 647.A.2 is hereby amended to add data centers within the C-2
(Intermediate Commercial), C-3 (General Commercial), CP/GCP (Commerce Park/General
Commerce Park), A-1 (Light Industrial) and A-2 (Industrial) zoning districts, with
performance standards to read as follows: 
Section 647. Special Permit Uses. 
*** 
A. 
Permitted uses. There shall be permitted, in addition to the uses enumerated in the
several use districts, certain additional uses subject to the requirements of this
section. 
*** 
 
2. 
A special permit may be granted by the Council upon recommendation of the
Commission to establish the following uses in the use districts named: 
*** 
 
KK. 
DATA CENTERS IN THE C-2, C-3, CP/GCP, A-1 AND A-2 ZONING 
DISTRICTS, SUBJECT TO THE FOLLOWING:  
 
(1) 
THE DEVELOPMENT SHALL BE NO CLOSER THAN 2,640 
FEET FROM AN APPROVED HIGH-CAPACITY TRANSIT
STATION. 
 
(2) 
PRELIMINARY SITE PLAN APPROVAL WILL NOT BE 
GRANTED FOR A DATA CENTER UNTIL SUCH TIME THAT
A 
LOCAL 
UTILITY 
COMPANY 
PROVIDES 
A 
CONTRACTUAL 
AGREEMENT 
THAT 
AFFIRMS 
ITS
CAPACITY AND COMMITMENT TO SERVE THE ENERGY
DEMAND FOR THE PROPOSED DATA CENTER.  THE
AGREEMENT FROM THE UTILITY COMPANY SHALL BE
SUBMITTED 
TO 
PDD 
CONCURRENT 
WITH 
THE
PRELIMINARY SITE PLAN. 
 
(3) 
THE FOLLOWING SHALL APPLY WHEN THE SITE IS
LOCATED WITHIN 300 FEET OF A RESIDENTIAL ZONING
DISTRICT:

12 
Ordinance G- 
 
(a) 
PRELIMINARY SITE PLAN APPROVAL FOR A DATA 
CENTER SHALL NOT BE GRANTED UNLESS IT HAS
BEEN DEMONSTRATED THAT THE DATA CENTER, 
INCLUDING 
ALL 
ON-SITE 
MECHANICAL
EQUIPMENT AND FACILITIES, WILL NOT EXCEED 
THE EXISTING AMBIENT NOISE LEVEL FOR THE 
SITE BY MORE THAN 5% OR A SPECIFIC NOISE
STANDARD MAY BE STIPULATED AS A CONDITION 
OF AN APPROVED SPECIAL PERMIT. 
 
(b) 
TO DETERMINE COMPLIANCE WITH THE PRIOR
SUBSECTION, THE DEVELOPER SHALL SUBMIT A 
NOISE 
STUDY 
TO 
PDD 
PRIOR 
TO 
OR 
CONCURRENT WITH THE PRELIMINARY SITE
PLAN.  THE NOISE STUDY SHALL BE PERFORMED 
BY A THIRD-PARTY ACOUSTICAL ENGINEER TO
DOCUMENT BASELINE NOISE LEVELS IN THE 
AREA OF THE PROPOSED DATA CENTER, 
INCLUDING NOISE LEVELS MEASURED AT THE
PROPERTY LINE OF THE NEAREST RESIDENTIAL 
ZONING DISTRICT TO THE PROPOSED DATA 
CENTER PROPERTY.  
 
(c) 
UPON APPROVAL OF THE NOISE STUDY, THE 
METHODS PROPOSED TO MITIGATE NOISE SHALL 
BE STIPULATED AS A CONDITION OF FINAL SITE 
PLAN APPROVAL. A FINAL CERTIFICATE OF 
OCCUPANCY SHALL NOT BE ISSUED IF THE 
AMBIENT NOISE EXCEEDS THE PRIOR EXISTING 
NOISE LEVEL BY MORE THAN 5%.

13 
Ordinance G- 
 
(4) 
THESE REGULATIONS AND THE DESIGN GUIDELINES 
SET FORTH IN SECTION 507 TAB A.II.D.5., DATA 
CENTERS ARE NOT APPLICABLE TO DATA CENTERS
WHICH HAVE RECEIVED FINAL SITE PLAN APPROVAL; 
OR A DATA CENTER USE THAT IS SPECIFICALLY LISTED 
AS A PERMITTED USE OR SPECIFICALLY DISCUSSED IN 
A COUNCIL ADOPTED PLANNED UNIT DEVELOPMENT
NARRATIVE PRIOR TO [THE EFFECTIVE DATE OF THIS
ORDINANCE]. OTHERWISE, THE DEVELOPMENT IS 
SUBJECT 
TO 
THESE 
REGULATIONS 
AND 
ALL 
APPLICABLE DESIGN GUIDELINES SET FORTH IN 
SECTION 507 TAB A, INCLUDING THOSE FOR SECTION 
II.D.5, DATA CENTERS. 
*** 
 
PASSED by the Council of the City of Phoenix this 2nd day of July, 2025.  
 
 
________________________________ 
 
 
 
    MAYOR  
 
 
ATTEST: 
 
 
____________________________City Clerk 
 
 
APPROVED AS TO FORM: 
 
____________________________City Attorney 
 
 
REVIEWED BY:  
 
____________________________City Manager