Attachment E - Technical Advisory Committee Membership, Meeting Summaries, and Presentations(PDF, 13MB)

— Regular Meeting (2026-06-03)

Extracted text (via pymupdf) 130082 characters

TAC Members and Participants
Technical Advisory Committee Members
Name
Area of Expertise
Organization/Aﬃliation
Lisa Shipek
Water / environmental
Watershed Management Group
Kate Hotten
Environmental
Coalition for Sonoran Desert Protection
Ed Hendel
Water/land use
Citizen's Water Advisory Committee
Chris Lindsey
Power systems and renewable energy
Tucson Electric Power
Chris Dougherty
Data center
Ark Data Center
Shawn Blubaum
Infrastructure and construction
Sundt
Jason Makansi
Land use regulations
Planning Commission liaison
Ryan Gruver
Data center operations
Banner Health - IT Director
Darin Gregg
Large scale data user
USAF Intelligence
Adria Brooks
Power systems and renewable energy
Grid Strategies, Dir. of Transmission Planning
Dan Stormont
Environmental
Commission on Climate, Energy & Sustainability
Joe Fico
IT Architecture
COT IT Architect
Josh Wright
Facilities Planning
U of A Chief Facilities and Planning Oﬃcer
Remy Franklin
Energy Equity
Interwest Energy Alliance
Staﬀ Technical Support (City of Tucson unless otherwise noted)
Name
Position/Role
Area of Expertise
Michael Catanzaro
Energy Manager
Electric power supply
Fatima Luna
Chief Resilience Oﬃcer
Resilience
Mike Czechowski
Senior Project Manager
Economic Development
Scott Schladweiler
Deputy Director, Tucson Water
Water Supply
Chris Avery
Principal Assistant City Attorney
Legal
Brad Borman
Principal Assistant City Attorney
Legal
Savannah Martinez
Emergency Manager
Emergency Management
Leslie Ethan
Section Manager
Sustainability
Anita McNamara
Pima County Development Services Dept.
Land use
Scott DiBiase
Pima County Dept. of Environmental Quality
Air quality
Planning and Development Services Team
Name
Position/Role
Area of Expertise
Daniel Bursuck
Planning and Development Services
Planning Administrator
Nicholas Martell
Planning and Development Services
Section Manager
Carver Struve
Planning and Development Services
Principal Planner, and Primary POC
Cesar Acosta
Planning and Development Services
Principal Planner
Ian Wan
Planning and Development Services
Lead Planner
Ina Ronquillo
Planning and Development Services
Public Information Oﬃcer
Facilitation Team
Name
Position/Role
Area of Expertise
Tahnee Robertson
Southwest Decision Resources
Facilitation and Outreach
Colleen Whitaker
Southwest Decision Resources
Facilitation and Outreach
Attachment E

City of Tucson Planning and Development Services
Data Center UDC Technical Advisory Committee - Meeting #1
November 17, 2025 | 4-6pm| PDSD Office, 4th Floor

Meeting Summary
Participants – See end

Participant Introductions
TAC members briefly shared their background/experience relevant to this process:

• Ed Hendel: Founder of a local company with lots of expertise in doing impact analysis of
data centers, including Project Blue.
• Shawn Blubaum: Works for Sundt, a builder of data centers.
• Lisa Shipek : Works for Watershed Management Group, which has expertise in local
watershed planning, policy and conservation work, and in-depth understanding of
Tucson Basin water issues. Also serves as a representative for CWAC (Citizens Water
Advisory Council).
• Chris Dougherty: Works as a solutions architect for data centers.
• Jason Makansi: A chemical engineer with 45 years of experience in energy and
electricity and process industries; also serving as a Planning Commission Liaison.
• Adria Brooks: Served on Biden’s data center team looking at national data center issues.
Has also worked for state commissions regulating state utility tariffs.
• Darin Gregg: Participating is in his private capacity as a DOD consultant. Helped to bring
in generative AI for imagery and threat analysis.
• Chris Lindsey: Has worked for 18 years on the planning side of TEP; recently working on
supporting data center conversations at TEP.
• Josh Wright: Participation is based on his previous roles as the City Manager of
Chandler, and work at the cities of Wickenburg and Marana. He helped author 2 of the 4
data center policies that the group was given as examples.
• Ryan Gruver: Chapter President of AFCOM (Association for Computer Operations
Management)

Getting Started: Shared Learning - Carver Struve, PDSD
Carver shared a presentation (link), pausing for questions and discussion throughout.
Discussion is captured here, presented by presentation section. PDSD responses are in sub-
bullets.

Background & Technical Advisory Committee Scope
• Will there be an effort to provide a general baseline level of information to the public
ahead of the public process (e.g. what data centers are, how they interact with their
environment, basic water and energy consumption)?

o Yes, PDSD will set up a website with information, and all public outreach and
meetings will include an educational component. There is some introductory
information on this today, and TAC feedback on what is most useful to share
with the public is desired.
• In reviewing the recording of the Mayor and Council meeting on this topic, it seems to
express a desire for us to look outside of the box, at more than just code. Perhaps on
things like utility tariffs or water applications. Is that correct, are we thinking that big?
o The primary role of this effort is to develop zoning code. However, there could
be additional TAC recommendations coming out of this, and we want to
document these. They could be utilized at the City as a whole, just not
necessarily as part of this process.

Data Centers Overview
Power Supply
• Correction on presentation: co-location center power supply - Ark is a colocation center,
and they are at about 5 MW, not 20-100 MW as noted in the slide.
• Note that centers often use multiple of these power sources, not just one.
• In addition to on-site generation there are sophisticated UPS, batteries, generators, etc.
• There may not be much wind or geothermal opportunity without being grid-tied. These
regional sources are outside of the City. We don’t want to mis-represent that this could
be done without the grid.
• What is listed on the power source type is primarily the fuel source, not where it is
coming from. Contracting with people off-site would be the case for most of the
renewables.

Water use
• Can we also look at the water use of all these power source types?
• Would like to also see energy usage for each of these cooling types. We’re essentially
shifting water use from onsite to offsite with these different energy types.
• Water free cooling is more energy intensive.
• The water usage of building a new national gas plant to power an air-cooled data center
uses more total water because of the water that is used to cool the new power plant.
This creates a shift from onsite to offsite use, with more total usage.
• Will there be an attempt to dovetail the Large Quantity Water Users ordinance with
this?
o Yes, coordination is important. This may tie back to the definition of a data
center. There may be some ability to discuss sustainability features for data
centers that could fit under the water ordinance.
• If we can’t regulate energy/water through zoning, can you touch other environmental
characteristics (e.g. emissions, water discharge)?
o Energy and water can be addressed, just in limited ways. Marana, for example,
was able to get no potable water use into their ordinance.
o Discharges are regulated elsewhere. But it could be possible to include here
provisions that data centers must comply with all other applicable permits as a

condition of approval. If it is regulated elsewhere, it could be a challenge to
make a more stringent regulation.

Additional comments
• The Arizona Corporation Commission (ACC) sill has an open docket on data center tariffs
and regulation. The City could choose to comment as part of this process.
• The ACC is just one of the regulating bodies. There are others. There is policy getting
discussed at other levels now; additions could be made here.
• Would it be possible to zone based off of activity? Then it might be possible to control
size by not allowing certain types (e.g. block chain) in certain areas.
o In one ordinance the PDSD team looked into they did look at activities, but these
were not regulated differently. You would need to create separate uses based on
data center activity. And the uses can change a lot. This would be really
challenging.
• Zoning off of activity would require constant revision and challenge.
• For public education it might be really helpful to position one of these data centers
within the pantheon of other “big boxes” in the desert, ex: an Amazon warehouse or
gas-fired power plant, or something else with lots of HVAC on top of it. For Project Blue
what people in the public were saying wasn’t always well-informed.
o We need a robust public education component for the community meetings; this
includes the website, which will have a good FAQ section.

Example regulations and core components in other jurisdictions
• How has Marana been able to regulate water use?
o The City’s Attorney’s Office shared that they may have done this with a specific
amendment to their water code. Perhaps it was part of a package that was
approved at the same time as the code amendment? A City could pass an
ordinance prohibiting potable water for cooling, as an inefficient use of water.
o What does Diesel Tier IV refer to in this code? It could be related to backup
generators.
• Do these regulations apply to all types of data centers?
o PDSD is thinking of a size threshold of 50,000 sq ft. Under this size it would be
regulated as something different.
• The terms PAD and specific plan have been used a couple times. Is this the zoning
designation, or is there alphabet below with overlay on top?
o Dan – this is this is similar to a Conditional Use Permit for Pima County.
• What does Mayor and Council want us to accomplish? The answer to some of the
questions posed depends on what the community wants - create an avenue for data
centers to harmoniously exist, or keep them away?
o It seems that they want PDSD to provide regulations that allow for the
sustainable development of data centers in a way that is in line with our
community values. They have specifically said this will be a Mayor and Council
Special Exception process – this is a process that is transparent, has public
component, and allows for site specific regulation.

• Another example to consider - Eastmark Special Zone (Phoenix).

Group Discussion
Members filled out a feedback form individually and then discussed. The form provided an
opportunity to weigh in on which of the possible regulation components are most important to
include, identification of remaining information needs and any missing perspectives in the TAC.
Information presented here includes both discussion and content from feedback forms.

Member ranking of regulatory component importance
Regulatory components were ranked as High (3), Medium (2), Low (1), with an option for
unsure (0). Results shown are average rankings.

Water
2.8
Energy
2.7
Noise
2.6
Air Quality
2.6
Generator operation
2.4
Design features
2.4
Heat
2.4
Vibration
2
Screening
1.9
Wildlife amenities
1.9
Glare
1.6
Design/Aesthetics
1.3
Location/setback
1.2

Overall comments
• Many of these components are related to each other. If we are confident in existing
standards and site review, these might not all be important to include.
• Identify what parts are already regulated in some fashion. May not need to get into
great detail, but instead reference existing regulations (e.g. air quality, water, energy).
• Some things are difficult to regulate well – vibration, heat. You might be setting yourself
up for failure if you try.
• We need to have hard caps instead of just fees for violations. These companies are so
wealthy that fees are not effective.
• There is a lot of misinformation about data centers on social media.
• The biggest enemy of data centers is time – they want them yesterday. If our process is
more cumbersome than another location, they will go elsewhere. There is more
demand than supply.

• What is our intended outcome? If we want to make it responsible, but relatively
difficult, we can write it that way. If they idea is to be pro-business, then it can be
written another way. Need clarity. From a zoning standpoint we need to make it
reasonable but with fairly significant hurdles to ensure there is a good solid process.
• AI inference – we are switching to this in next 2-3 years. There will be a lot more micro
data centers. This is coming and we need to think about this.

Additional components to consider
• The City’s economic development goals and how this supports, or doesn’t support,
these.
• The tax structure for data centers and what benefits they would provide, as well as
other community benefits that could be negotiated. That is hard to codify, but there
could be a policy framework council could adopt around this, especially if zoning is going
to be the key. The profit margins are astronomical, so you can ask for a lot.
• Acoustical engineering may come up; it’s unusual and complicated.
• A big issue for users is access.
• Data center operations can result in a lot of reliability issues for the rest of the grid –
more discussion needed here.
• Groundwater impacts
• Remediation of lands after retirement of data centers
• AI safety - Unsure how much of this can be done through zoning, but it is critical.
Hyperscale data centers are designed to create AI that is smarter than humans. We
need a Manhattan Project level of security. If the centers will be used for training AI, we
need guard rails.
o Propose we require attestation from operator if the center will use more than 10
to the power of 26 FLOPS (floating-point operations per second). This likely
correlates with whether or not it is hyperscale. CA laws and bills have figured out
how much flops would be used to create AI. We can piggyback off of these.
o Need to include: implement weight security models in zoning, audited attempts
to hack into weights, whistleblower protections.

Water and Energy
• Water is clearly the most important thing. Energy is also important, but the City isn’t the
power provider, so TEP has to resolve this.
• Need to ensure we really understand the Large Quantity Water User piece and that
these efforts are in alignment. This is very important. This is the other hammer.
• Must tie this to whatever is happening with the Large Quantity Water User ordinance.
• How they are cooled dictates how much energy they use. This has to be figured out
(although maybe it’s not this committee). If you don’t use water to cool, then you’re
using energy to cool (using water upstream). If you can put power back in the grid and
use air, what is that impact?
• Anti data center folks will go down the path of water and energy; pro data center will
say it creates jobs; this is true, and they are good paying.

• Onsite generation – if we want to future proof this, we may want to come back and
revisit it in a few years. What does this look like? Natural gas?
• Could runoff from the roofs be used (positive impacts to wildlife and native landscaping)

Generator operation
• Need to consider a fuel storage plan for backup generators.
• The biggest issue with generators is around maintenance and noise. Can restrict use
from 9-5. Fuel storage is pretty self-contained.
• Can we limit operational hours for backup generators?
• Some data center operators act as VPPs, feeding power back into the grid from their
generators. Would be concerned about regulation of those hours.
• Load shedding (having to drop off the grid to stabilize) - does this need to be included?

Noise
• Inside the buildings it is a big issue.
• In interviews with community members in other places, everyone complained about
this.
• Everyone says they are loud, but they’re not in my neighborhood. Only hear them when
there is a power failure, but this almost never happens.

Design
• If we are going to enable these types of projects, how do they fit in and compliment the
surrounding area? Design, screening, etc. are helpful for this.
• Considering aesthetics is important – don’t want them to look like a concrete box. Some
can look nice, and you have a lot of leverage on the developer to dictate this. They are
worth so much money, you can get a lot from them (metal panels, nice glass, etc.)
• Aesthetics balance is important - the BICSI 002 manual provide guidance on setbacks,
camera placement, fencing, lighting, and similar elements

Setbacks
• This Has to be addressed. People want them at a reasonable distance. If they will be in
industrial areas, we can address how far they are from residential zoned areas.
•
Not in the 500-year historic floodplain.

Air Quality
• Can probably designate a higher level of Environmental Protection.

Vibration
• Owner/operators don’t like vibration. We want to avoid this, as it causes parts to fail.

Additional information needs for the TAC
• Examples and lessons learned
ο From highly regulated jurisdictions (e.g. CA), and lightly regulated jurisdictions
(e.g. Alabama)
ο Lessons learned from others who have zoned large industrial sites like this

ο How are the other codes working out? Three of the four examples shared
already had data centers when they were written; their codes were trying to
address the problems they had with existing centers.
• Large Quantity Water Users Ordinance
ο How this effort will interact with what the water code committee is creating.
Could be very important before finalizing zoning requirements.
• Zoning info
ο What can we require of data centers through zoning?
ο Understanding how zoning interfaces with groundwater access and use
• Stats
ο Number of data centers in Tucson today. How are they working out?
ο Typical energy balances around a large-scale data center
• TAC guidance
ο Overall goals
ο Intended outcome; more direction from M&C
• Future considerations for on-site or adjacent generation such as nuclear microreactors
or advanced natural-gas systems.
• How does zoning interface with groundwater access and use?

Missing perspectives or expertise for the TAC
• Life cycle sustainability analysts
• Acoustical engineering (maybe, if that becomes focus of group)
• Construction managers
• Neighbors/community member needs (bus stops, shade, sidewalks)
•
Data center security - this is important as owner/operator. How do we allow people to
balance security with aesthetics of the site?
• AI safety (already on TAC)
• Neighbors who may end up being near data centers - what are their needs adjacent to
the property line (e.g. bus stops, shade structures, etc.)?

Participants
(* = virtual participation)

TAC Members
Lisa Shipek
Watershed Management Group
Ed Hendel
Citizen's Water Advisory Committee
Josh Wright*
UA Chief Facilities and Planning Officer
Chris Lindsey
Tucson Electric Power
Chris Dougherty
Ark Data Center
Shawn Bluebaum
Sundt
Jason Makansi
Planning Commission liaison
Ryan Gruver*
Banner Health - IT Director
Darin Gregg
USAF Intelligence
Adria Brooks
Grid Strategies, Dir. of Transmission Planning

Staff/Technical Support
Fatima Luna
Chief Resilience Officer
Mike Czechowski
Economic Initiatives
Scott Schladweiler
Tucson Water
Michael Catanzaro*
COT Energy Manager
Savannah Martinez
COT Emergency Manager
Anita McNamara*
Pima County Development Services Department
Scott DiBiase
Pima County Department of Environmental Quality
Brad Borman*
City Attorney's Office
Chris Avery
City Attorney's Office
Teresa Smith
Ward Office Staff – Ward 4
Eryck Garcia
Mayor’s Office

PDSD Team
Daniel Bursuck
Planning Administrator
Nicholas Martell
Section Manager
Carver Struve
Principal Planner, and Primary POC
Cesar Acosta
Principal Planner
Ian Wan
Lead Planner
Ina Ronquillo
Public Information Officer

Facilitation: Southwest Decision Resources – Tahnee Robertson, Colleen Whitaker

Technical Advisory Committee Meeting
Large-Scale Data Centers
November 17, 2025

Meeting Overview
• Introductions
• Background and Technical Advisory Committee
• Zoning Overview
• Data Center Basics
• Data Center Regulations in Other Jurisdictions
• Group Exercise
• Next Steps Including Set Next Meeting Date

Introductions
• Name
• Relevant Affiliation for TAC
• Expertise related to data
centers or their impacts

Background and Technical Advisory Committee

Background
• August 6, 2025 - Mayor and Council direct staff develop a Unified
Development Code (UDC) amendment for large-scale data centers
• Followed consideration of the Project Blue proposal
• Directed to establish standards and an approval process
• Completing comprehensive research into the potential impacts of data
centers and regulations in other communities

Progress to Date
• Mayor and Council Initiation
• Zoning Administrator Determination
• Large Quantity Water User
Ordinance
• Preliminary Planning Commission
Study Session
• Formed Technical Advisory
Committee
Image: KVOA

First Planning
Commission
Study Session
Technical
Advisory
Committee and
Community
Engagement
Draft Proposed
UDC
Amendment
Second
Planning
Commission
Study Session
Planning
Commission
Public Hearing
Mayor and
Council Public
Hearing and
Consideration
Mayor and
Council
Initiation
UDC Amendment Timeline
Sept. 2025
Nov. to
Dec. 2025
January 2025
February
2026
March
2026
April 2026
August 6, 2025

Technical Advisory Committee (TAC) Role
• Share knowledge and expertise
• Discuss key issues related to land use, environment, and infrastructure
• Learn about and provide input on best practices, new technologies, and
approaches from other cities
• Advise on options for regulating large-scale data centers
• Recommend topics and standards for inclusion in a UDC amendment,
which staff will draft for public review, Planning Commission
recommendation, and Mayor and Council action

TAC Composition
• Includes 11 members with local knowledge from various technical fields
• Staff and technical support from relevant City / County departments
• Areas of expertise include
• Environmental resources
• Water Supply
• Power Supply
• Data Center Construction
• Data Center Operations

TAC Outcomes
• Development of a recommended code amendment from various
technical perspectives
• Strive for common ground, even when there is disagreement
• Understand and document areas of agreement and disagreement
• Stakeholder engagement follows TAC input and recommendations

Questions:
Background and Technical Advisory Committee

Zoning Overview

Zoning Overview
•
Sets permitted uses and development
standards for each land use designation
through the City’s Unified Development Code
•
Designations shown on City’s legally adopted
zoning map
•
Establishes regulatory requirements related to
land use and development
•
Specifies how each piece of land is to be
developed consistent with overarching policies

What Can Zoning Regulate
State of Arizona prescribes what cities and towns can regulate through zoning
under ARS 9-462.01
•
The City can regulate:
• Land use
• Building size, shape, height, materials, and purpose
• Site dimensions, setbacks, lot coverage
• Location and use of buildings and land
•
Water and Energy use are not identified as areas that can specifically be
regulated by zoning
•
How we define data centers is critical to their regulation through zoning

Mayor and Council Special Exception
•
Process to review and approve uses that could affect nearby
properties if not properly managed
•
Not automatically allowed; may be approved after detailed review and
public input
•
A Mayor and Council special exception is a more stringent review
process
•
Requires a design compatibility report, neighborhood meeting(s), a
Zoning Examiner public hearing, and Mayor and Council consideration
•
Must conform with Plan Tucson 2025, and applicable neighborhood
and area plans

How Tucson Currently Regulates Data Centers
• Existing Code designates a storage use, historically applied to
smaller data centers
• Recent Zoning Administrator Determination Letter defined large-
scale data centers as a Utility: Generating System Use
• Clarifies current condition with a documented process
• Intended to be applied short-term until code amendment
completed
• Planned Area Development (PAD) would be required under
current zoning

Questions:
Zoning Overview

Data Center Basics

What is a Data Center
• A warehouse filled with thousands of
computers working 24/7 to store,
process and deliver digital services
• Data centers house computer systems,
networking equipment, and storage
devices which power the digital world
Image: NBC News

Key Components of Every Data Center
•
Server Racks Tall metal cabinets that stack servers
vertically for efficient space, airflow, and cable
management
•
Networking Equipment Devices (switches, routers,
firewalls) managing fast, secure data flow between
servers and external connections
•
Storage Systems Storage hardware (HDDs & SSDs)
often in redundant arrays that provide reliable data
storage
•
Power Infrastructure UPS, backup generators, and
PDUs providing continuous power during outages
•
Cooling Systems Sophisticated HVAC systems
designed to remove the enormous amounts of heat
generated by thousands of computing devices running
continuously.
Image: Data Center Magazine

Data Center Types
Edge / Micro
• Power Range: < 1 MW
• Purpose: Real-time processing close to users
• Location: Near population centers or infrastructure nodes
• Use Case: IoT, autonomous vehicles, smart city applications
• Size: Compact footprint (500–5,000 sq. ft.)
Enterprise
• Power Range: 1–20 MW
• Purpose: Internal IT operations for a single organization
• Location: On-premises or dedicated off-site
• Use Case: Corporate data, finance, healthcare, education
• Size: (1,000–10,000 sq. ft. or up to ¼ acre)
Colocation
• Power Range: 20–100 MW
• Purpose: Shared infrastructure for multiple clients
• Location: Commercial zones or industrial parks
• Use Case: Hosting, HPC, secure multi-tenant environments
• Size: (10,000–100,000+ sq. ft. or 1/4 acre to 2+ acres)
Hyperscale
• Power Range: 100+ MW
• Purpose: Massive cloud-scale operations
• Location: Remote or utility-optimized sites
• Use Case: AWS, Google Cloud, Microsoft Azure, AI workloads
• Size: (100,000–4,000,000+ sq. ft. or 2 to 100+ acres)

Edge Data Centers
Image: Taylor Vick on Unsplash
Image: Ismail Enes Ayhan on Unsplash

Enterprise Data Centers
Image: Google Street View
Image: Google Street View

Colocation Data Centers
Images: Google Street View

Hyperscale Data Centers
Image: QZ.com
Image: Associated Press

Power Source Types
Grid-Tied Electricity
• Power Range: Flexible (1–100+ MW)
• Purpose: Primary power from utility providers
• Location: Anywhere with robust grid infrastructure
• Use Case: Most enterprise, colocation, and hyperscale
centers; often paired with backup systems
On-Site Generation (Natural Gas / Diesel)
• Power Range: 5–50 MW
• Purpose: Backup or primary generation for reliability
• Location: Industrial zones with fuel access
• Use Case: Redundancy, peak shaving, or off-grid operation;
common in Tier III/IV facilities
Renewables (Solar / Wind / Geothermal)
• Power Range: 1–20 MW (scalable)
• Purpose: Sustainable, low-emission energy
• Location: Solar-rich zones, wind corridors, geothermal fields
• Use Case: Edge and enterprise centers; increasingly used in
colocation and hyperscale with storage
Emerging Technologies (Fuel Cells / Small Nuclear
Reactors / Microgrids)
• Power Range: 1–100+ MW (modular)
• Purpose: Innovative, resilient, and scalable power
• Location: Pilot zones, innovation districts, remote
deployments
• Use Case: Future-proofing hyperscale and mission-critical
sites; supports decarbonization goals

Water Use Categories

Water / Energy Use and Zoning
• ARS 9-462.01 does not allow for the regulation of water and
utilities though municipal zoning
• Water use is being regulated through the City’s Large Quantity
Water Users Ordinance
• Utilities are generally regulated by the Arizona Corporation
Commission (ACC)

Large Quantity Water User’s Ordinance
Purpose of Ordinance 12188
• Created a Large Quantity Water User Program for new water
connections and meter upsizing requests
• Mayor and Council direction to strengthen water conservation
for major water users
• Became effective August 19, 2025, with a request for further
review and update
• Ad Hoc Committee with 42 representatives formed to advise
City on potential changes

Arizona Corporation Commission
• Regulates investor-owned electric utilities
• Sets and approves electricity rates
• Oversees utility resource and infrastructure planning
• Enforces renewable energy and efficiency standards
• Reviews financing, mergers, and major projects
• Ensures reliable service and protects consumers
• Any proposed regulation of energy use through zoning
needs to be carefully crafted and would require legal
evaluation.

Questions:
Data Center Basics

Data Center Regulations in Other Jurisdictions

Example Codes from other Jurisdictions
Per Mayor and Council’s direction, City staff has reviewed data
center regulations from other jurisdictions including:
• City of Chandler
• Town of Marana
• City of Mesa
• City of Phoenix

Comparison of Data Center Regulations
Regulatory Area
Chandler
Marana
Phoenix
Mesa
Definition
Broad definition; networked systems,
telecom, data storage/processing
Broad; servers, utilities, digital data
management
Includes only primary-use facilities;
small owner-only uses excluded
Very broad; includes advanced
operations (AI, blockchain, crypto,
modeling)
Where Allowed
Principal use only in PAD; accessory
with limits
Principal via Specific Plan; accessory in
LI/HI
Only select zones with Special Permit
Principal via PAD Overlay; accessory
allowed under conditions
Community Input
Neighborhood notice + meetings
required
Neighborhood notice required
Noise mitigation required near
residential; no formal meetings
PAD review includes input; not
explicitly required
Noise Requirements
Baseline + post-construction + annual
monitoring; mitigation; liaison
Baseline + post-construction + annual
monitoring; max levels by use
Noise study within 300 ft of
residential; mitigation required; max
5% increase
General operational compliance;
enforcement tied to occupancy
Site & Building Design
Setbacks, screened equipment,
landscaping, architectural treatments
Setbacks, screening, underground
utilities, landscape buffers, building
mass/height limits
Setbacks (150 ft mechanical),
landscape buffers, façade treatments,
streetscape, shaded paths
Setbacks, PAD standards, landscape
buffers, massing/façade treatments;
flexible via PAD
Backup Power / Generators
Restricted hours, notice, sound
mitigation
Diesel Tier IV, emergency use, limited
hours
Screened/setback; must meet noise
limits
Covered under operational/PAD
review
Utilities / Water
Considered during PAD review
Must demonstrate adequate
electricity/water; potable water
prohibited for cooling
“Will-serve” letter; water source
documentation
Reviewed during PAD/special approval
Parking & Transportation
Not specified in code amendment
Not specified in code amendment
Minimum distance from transit;
streetscape/shaded paths
Minimum parking ratios defined
Enforcement
Conditional on PAD + ongoing noise
monitoring
Compliance tied to Specific Plan;
annual monitoring
Certificate of occupancy conditional
on noise compliance
Civil penalties; escalating fines for
repeat violations; habitual offenders
may face criminal charges

City of Chandler
Regulatory Area
Requirements
Definition
Broad definition; networked systems, telecom, data
storage/processing
Where Allowed
Principal use only in PAD; accessory with limits
Community Input
Neighborhood notice + meetings required
Noise Requirements
Baseline + post-construction + annual monitoring; mitigation; liaison
Site & Building Design
Setbacks, screened equipment, landscaping, architectural
treatments
Backup Power / Generators
Restricted hours, notice, sound mitigation
Utilities / Water
Considered during PAD review
Parking & Transportation
Not specified in code amendment
Enforcement
Conditional on PAD + ongoing noise monitoring

Town of Marana
Regulatory Area
Requirements
Definition
Broad; servers, utilities, digital data management
Where Allowed
Principal via Specific Plan; accessory in LI/HI
Community Input
Neighborhood notice required
Noise Requirements
Baseline + post-construction + annual monitoring; max levels by use
Site & Building Design
Setbacks, screening, underground utilities, landscape buffers,
building mass/height limits
Backup Power / Generators
Diesel Tier IV, emergency use, limited hours
Utilities / Water
Must demonstrate adequate electricity/water; potable water
prohibited for cooling
Parking & Transportation
Not specified in code amendment
Enforcement
Compliance tied to Specific Plan; annual monitoring

City of Phoenix
Regulatory Area
Requirements
Definition
Includes only primary-use facilities; small owner-only uses excluded
Where Allowed
Only select zones with Special Permit
Community Input
Noise mitigation required near residential; no formal meetings
Noise Requirements
Noise study within 300 ft of residential; mitigation required; max 5%
increase
Site & Building Design
Setbacks (150 ft mechanical), landscape buffers, façade treatments,
streetscape, shaded paths
Backup Power / Generators
Screened/setback; must meet noise limits
Utilities / Water
“Will-serve” letter; water source documentation
Parking & Transportation
Minimum distance from transit; streetscape/shaded paths
Enforcement
Certificate of occupancy conditional on noise compliance

City of Mesa
Regulatory Area
Requirements
Definition
Very broad; includes advanced operations (AI, blockchain, crypto,
modeling)
Where Allowed
Principal via PAD Overlay; accessory allowed under conditions
Community Input
PAD review includes input; not explicitly required
Noise Requirements
General operational compliance; enforcement tied to occupancy
Site & Building Design
Setbacks, PAD standards, landscape buffers, massing/façade
treatments; flexible via PAD
Backup Power / Generators
Covered under operational/PAD review
Utilities / Water
Reviewed during PAD/special approval
Parking & Transportation
Minimum parking ratios defined
Enforcement
Civil penalties; escalating fines for repeat violations; habitual
offenders may face criminal charges

Key Takeaways from Jurisdictions
•
All jurisdictions require some form of approval process such as a planned
area development
•
All jurisdictions require demonstration of adequate utility capacity,
including water and electricity
•
Marana prohibits use of potable water for cooling
•
Chandler has the most robust engagement, requiring both notice and
neighborhood meetings
•
Mesa has the most extensive definition, covering different technologies
such as ai, blockchain, and crypto
•
Phoenix includes more robust noise mitigation requirements

Potential Components of UDC Amendment
•
Data center definition, including a size threshold for large-scale data
centers
•
Required Mayor and Council Special Exception process for large-scale
data centers
•
Establishing zoning districts where large-scale data centers are
permitted
•
Potential use specific standards
•
Other considerations as identified through Planning Commission
feedback, the Technical Advisory Committee, and community
engagement process

TAC Role within the Code Amendment Process
• Seeking input / experience on codes from the other jurisdictions
• What questions/concerns do you think people will have about this?
• What is coming next in terms of the technology that we should
build into the code?
• What in the other codes should we seek to emulate?
• What in the other codes should we seek to avoid?

Questions:
Data Center Regulations in Other Jurisdictions

Group Exercise

Group Discussion
1.
What regulations and standards do you think are most important to
include in the proposed code?
2. Do you feel there is additional information we need to effectively
move forward.
3. Are there any other areas of expertise that should be included in TAC
discussions?

Next Steps
• Establish Next Meeting Date
• Meeting 2: Review concepts for inclusion in draft
Amendment
• Meeting 3: Review and finalize draft amendment

Thank You!
Carver Struve
Principal Planner
Planning and Development Services | City of Tucson
phone 520.837.4929
email carver.struve@tucsonaz.gov

1
City of Tucson Planning and Development Services
Data Center UDC Technical Advisory Committee - Meeting #1
December 15, 2025 | 4-6pm| PDSD Office, 4th Floor

DRAFT Meeting Summary
Participants - see end

Next steps
•
Next meeting: January 12

Introductions
Three members who were not present at the last meeting introduced themselves:
•
Remy Franklin (Interwest Energy Alliance) – Remy is representing himself, not EIA. He has
worked on electric utility regulation in Arizona and other states, and on multiple issues,
including data centers.
•
Dan Stormont (CCES)- Dan is the chair of the CCES and is computer engineer by training. He has
been involved in a number of sustainability related efforts in Tucson, including Sustainable
Tucson.
•
Kate Hotten (Coalition for Sonoran Desert Protection) – Kate is the co-ED of CSDP and is
representing environmental interests on the TAC. In the past she also worked for a tech
company that located data centers in Ireland.

Additional Context on Key Code Topics
Carver shared a short presentation (link) providing additional context on key topics including
development agreements, and use specific standards. A discussion summary is presented here; PDSD
responses to questions are in sub-bullets.

Development agreements
There are voluntary agreements between a property owner and the City. These are not required. They
do not dictate or superseded zoning, but can provide guidance as development occurs. PDSD has been
consulting the City Attorney’s Office, and it seems this can’t likely be required as part of the zoning code
amendment.
•
Can the TAC create a recommended Development Agreement for Data Centers? This could
potentially include things that can’t be part of land use that we want to recommend, for
example recommendations for engaging with a hyper-scaler.
o The City doesn’t have the authority to require a development agreement. But if there
are considerations that may be relevant, we should catalogue those as part of this
process. We can document those things that can’t be addressed in code and share with
Mayor and Council. and present these potential items to include in a DA to M&C.
•
What are the legal constraints for requiring a development agreement? Under what conditions
would one be used? Note that there was one for Project Blue. Could we establish an energy use
threshold for when one would be required?
o The City Attorney’s Office says we can’t require it as part of a Special Exception process.
It’s a voluntary agreement. We can provide guidance to data centers as they reach out
to explore development.

2
Potential Regulatory Topics - Discussion
Topics for discussion were summarized in a handout that introduced each topic, summarized PDSD’s
current thinking on the approach for the topic, and identified areas for RAC feedback and discussion.
The group made it through the first five topics in the handout, and agreed to reconvene and continue
discussion of the topics at the next meeting. For each topic a brief overview is provided, followed by a
summary of group discussion.

Topic 1: Data Center Definition
The Zoning Administrator’s determination includes a definition that was based on consideration of the
other four jurisdictions being reviewed. This was a short-term determination, and is a good starting
point for discussion

Size threshold
•
Most members felt that some type of size threshold is appropriate and discussed how size
should be defined.
o Megawatts used? Total footprint? Number of servers?
o The Zoning Administrator used 50,000 sq ft of the gross floor area. PDSD shared that it
needs to be easily measured, something that doesn’t fluctuate a lot and that is
enforceable. Energy usage might be challenging to enforce.
o 50,000 sq ft. would still be a pretty small facility.
•
Concerns with an energy threshold; support for square footage threshold:
o People can game the numbers (i.e. lots of requests for just under the threshold). The
square footage concept is preferable because it is easily measured.
o According to TEP there isn’t a single number that defines hyperscale, but they have all
been huge (500 MW or a GW or more).
o A developer could build out multiple smaller sites, just under the threshold.
o There are many competitive industries like data centers that don’t want to disclose their
utility consumption because they think people will back calculate sensitive performance
aspects. This could be an issue with anything except the square footage concept.
•
Additional considerations:
o There are lots of different sizes of data centers. We shouldn’t only be thinking about
zoning for hyperscale; we may need to be less prescriptive.
o We should think about what land use impacts are very prevalent at specific sizes; we
need to consider impacts to the location and adjacent properties.
o There is industry standard language that could be used and would lend itself to the
scale/size. It wouldn’t tie to megawatts, but the type of facilities that would be utilized
to serve the scale. One option is to talk about voltage classes that would make it general
enough and not tie us down in future. There seemed to be interest in exploring this
approach.

Tiered sub-class
•
What is the objective? Many small data centers will just serve queries and may be close to a
university or in a neighborhood. Are we trying to apply different standards to this and
something like Project Blue?
•
The hyperscale facilities have much more pronounced impacts.

3
•
At least one member was in favor of a tiered sub-class, and suggested it also include the water
and energy infrastructure that has to be developed.
•
One of the biggest land use impacts of large data centers is having to develop new
infrastructure.
o PDSD noted that infrastructure may be included in co-location incentives.

Inclusion of specific activities
•
This approach was strongly discouraged by a couple members who felt that what goes on inside
is up to the business, and many of these things are very hard to understand and regulate (i.e. AI,
block chain, etc.)
•
Another member was more comfortable including specific activities if the language stays
flexible, i.e. “These operations may include….”

Topic 2: Permitted Zoning
Topic overview
The goal is to minimize the impacts of large-scale data centers on surrounding land uses. There are a
couple options in the zoning code that are best suited to this (I-1 and I-2). These are designed for uses
that have significant impacts on surrounding land uses (e.g. noise, light traffic). There are also other
zoning regulations (PAD, PCD) that could potentially be worked into any code proposal and would allow
special one-off approval process for data centers in specific areas. Under these provisions we would look
at the specific impacts of a data center.

Discussion
•
Do we want to try to aggregate all data centers into a specific area using a PAD or PCD?
o There could be an attempt to incentivize this, but a PAD may not achieve this. If we feel
this is only appropriate in certain areas, we could include in the code a geographic
region where they are allowed. This is being done now with Middle Housing.
•
How is a PCD different than a PAD?
o A PCD is essentially a larger PAD with mini-PADs within it. It’s intended for large
developments (~500k acre). It has not been used that often.
•
It looks like the industrial zones generally follow I-10. How does that comport with the City’s
economic planning and initiatives?
o Much of the City’s existing industrial is already built out. There is not a lot of room for
hyperscale development. Most of the room is in the Southlands. This was the area that
was being targeted for Project Blue, due to its isolation.
•
Proliferation of data centers
o Josh shared that in his experience in Chandler, data centers tend to proliferate. In areas
that were zoned to allow for data centers they just began to come in and take over until
eventually everything was a data center. It’s not immediately clear how to address this,
but it would be good to discuss as part of this process.
o In the recent example with the County we saw this as well; they thought they were
approving perhaps one data center. There needs to be clarity that there isn’t so much
flexibility in the PAD that it ends up getting approved as something it’s not.
o The City shared that if they were to do an isolated data center campus they would want
it to be two miles from any other development. But then there are other issues with
provision of utilities.

4
•
The physical infrastructure of data centers fit into light industrial, but the utilities do not. Do we
want to consider another category?
•
Typically, a data center could only be zoned as I-1 or a PAD. It doesn’t make sense as I-2.

Topic 3: Public Notice Process
Topic overview
The Mayor and Council Special Exception requires a neighborhood meeting and notice within 400 feet.
Noise is a consideration here. Do we want to extend the notice area, and also potentially notice all
Neighborhood Associations (NAs)?

Discussion

Expanded noticing and meetings
Overall members felt that much broader noticing is needed, and discussed different aspects of how to
achieve this:
•
Given response to Project Blue we need to let everyone know about these applications.
•
Could expand notice radius to maybe a mile.
•
In addition to Neighborhood Associations, we should include relevant advisory groups.
•
All wards should be noticed.
•
More than one community meeting is important. One member encouraged three meetings.
•
Not all meetings need to be in person, virtual is an option as well. This could be written into the
ordinance.
•
Chandler has an HOA noticing requirement; it has been hit or miss if they share it with their
residents.

Noticing methods
•
Members discussed the limitations of paper mailers. Some felt that people just don’t see them.
The City shared that they are expensive and may not offer the best return on noticing.
•
Chandler has a social media requirement for noticing in all zoning cases. This has increased the
reach dramatically. Members were interested in this idea.
•
The City could develop a portal where groups could sign up to be notified for things like this; it
wouldn’t be that hard to do and could be very beneficial. There are many groups that would
want to be noticed for data centers but aren’t part of Neighborhood Associations.

Public education and communication
•
We should encourage public education, not just notice. Project Blue was horrible from the
public education viewpoint. We want to avoid misinformation and disinformation.
•
The City needs a comprehensive plan for communication, not just noticing alone.

Additional considerations
•
One member cautioned that whatever we do is going to apply to all data centers, not just the
hyper-scale ones that seem to be more of the focus of the discussion.

Topic 4: Development Standards for further Discussion
Topic overview

5
Members prioritized the following topics during the first meeting. These are presented here in order of
importance. Many of the items that were indicated as most significant to address may have the least
ability to be regulated through zoning. However, we may actually have a lot of ability to regulate some
of the topics that ranked lower (e.g. design features).

The group began discussion of these but did not complete all topics.

Topic 4.1: Energy Consumption and Sourcing
Adequate energy supply
•
Members wondered if this provision would be legal, given that it sounds like code can’t regulate
energy and water supply.
o The City clarified that we can’t regulate the amount of water or energy that is used, but
can require that there is adequate infrastructure for the development.
•
Could we require that they have the full energy provision in place within two years?
o From where TEP sits now, development of new generation is required for anything at
this large scale. This takes a lot of time; longer than building one of these facilities.
Studies that are done on the front end (impact studies and facility studies) are required
at this scale across the board. A study is good for about a year before signing. There is a
backlog now, so a requirement of two years wouldn’t likely be possible now.

Sustainability discussion
•
Many of the Project Blue concerns were that meeting their water and energy requirement
would compromise other City sustainability goals. Can the adequacy statement say - “must
demonstrate adequacy, without compromising the City’s other plans?” Explicitly detailing this
could be important.
o The Large Quantity Water User process does include reference to the City’s Climate
Action Plan and other plans. More clarification from the City Attorney’s Office would be
needed to see if this could be done.
o Members encouraged the City to make direct reference to the Large Quantity Water
User ordinance in this code. These things are intimately interwoven.
•
There is nothing in the Plan Tucson language that applies to a commercial user in the City. Can
we think of ways to encourage this?
•
This is very important. We do not want to use high water or high pollution energy sources. The
City should use all the tools available to ensure this aligns with our sustainability goals. The state
energy policy has very different priorities than Tucson and TEP.
•
The energy mix can’t be regulated as part of this; it usually gets defined in the Integrated
Resource Plan. Developers don’t have control over what the ACC does; we can’t require
sustainable energy.
•
We should consider a net-zero zoning policy for water. This is an up-and-coming idea. Maybe
the approach should be to say that the facility would need to be net-zero water, including their
energy use. This doesn’t tell them how much water or energy, just that they have to fully offset
the use.
•
We could try to include this as a condition in the development agreement. An additional option
might be to ask the applicant to submit a statement about their proposed energy mix. We could
state that this is not a reason for approval or denial, but it could be a required disclosure as part
of the application package. Then it at least serves as a prompt to discuss it in the development
agreement.

6
o PDSD will continue to work with the City Attorney’s office on how to frame this to get at
the intent of not compromising our other goals and how we could include a statement
as suggested.
•
Should we require air-cooled only?
o This is very nuanced. Project Blue is air-cooled now and will use more water.
o We need to focus on water impact, not absolutely one thing or the other.
o If the power is from low water clean sources, then it should be air-cooled.
o Potable water use is low in water-cooled centers (they have less employees, fewer
toilets, sinks, etc.). We are potentially causing issues upstream from the development.

Topic 4.2: Water Use and Sourcing
Time allowed only initial discussion on this topic.
•
Net-zero water usage would include energy. There are other City’s that have net-zero water
policies (e.g. Santa Fe)
•
PDSD will talk to Tucson Water about how net-zero water might be addressed or included.

Participants

TAC Members
Lisa Shipek
Watershed Management Group
Ed Hendel
Citizen's Water Advisory Committee
Josh Wright
UA Chief Facilities and Planning Officer
Chris Lindsey
Tucson Electric Power
Chris Dougherty*
Ark Data Center
Shawn Bluebaum
Sundt
Jason Makansi
Planning Commission liaison
Ryan Gruver*
Banner Health - IT Director
Adria Brooks
Grid Strategies, Dir. of Transmission Planning
Remy Franklin
Interwest Energy Alliance
Kate Hotten
Coalition for Sonoran Desert Protection

Staff/Technical Support
Fatima Luna
Chief Resilience Officer
Mike Czechowski
Economic Initiatives
Michael Catanzaro*
COT Energy Manager
Savannah Martinez*
COT Emergency Manager
Anita McNamara*
Pima County Development Services Department
Scott DiBiase*
Pima County Department of Environmental Quality
Brad Borman
City Attorney's Office
Teresa Smith
Ward Office Staff – Ward 4
Eryck Garcia
Mayor’s Office

PDSD Team

7
Daniel Bursuck
Planning Administrator
Nicholas Martell
Section Manager
Carver Struve
Principal Planner, and Primary POC
Cesar Acosta
Principal Planner
Ian Wan
Lead Planner

Facilitation: Southwest Decision Resources – Tahnee Robertson, Colleen Whitaker

Technical Advisory Committee Meeting
Large-Scale Data Centers
Meeting 2
December 15, 2025

Meeting Overview
• Welcome and Introductions
• Additional Context for key Code
Topics
• Potential Code Topics
Discussion
• Next Steps
Source: Shutterstock.com

Additional Context for Key Code Topics

Mayor and Council Direction
Initiate the public process required for the consideration and approval of
amendments to the City’s Unified Development Code for the purpose of
updating zoning requirements that apply to large-scale data centers in
order to safeguard public health and safety. This amendment will include
a clear definition of data center, and the design and development
regulations and standards that apply to them and will be informed by
examples of similar requirements adopted or under consideration
elsewhere in Arizona, including but not limited to Phoenix, Chandler, Mesa,
and Tempe. The amendments will also require that applications are
reviewed under Zoning Examiner Legislative Procedure which requires
approval by Mayor and Council after recommendation by the Zoning
Examiner.

Zoning vs. Building Codes
Zoning
• Governs Land Use (what can
go where)
• Sets limits on building size,
height, setbacks, parking, etc.
• Focuses on compatibility with
surrounding land uses and
long range planning goals
Building Codes
• Govern how structures are
built
• Set safety standards for
construction, materials and
building systems
• Focus on protecting health,
safety and accessibility
during construction and
occupancy

Use Specific Standards (Zoning)
• Additional regulations that apply to particular land uses beyond base
zoning standards
• Tailored to address unique impacts or operational characteristics of a
specific use, can be viewed as conditions of approval
• Provide clear requirements how certain uses must operate or be
designed
• Help reduce impacts to neighboring land uses (noise, traffic, odors, etc.)
• They do not address project specific discretionary decision or unique
site conditions

Development Agreements
• Voluntary contract between property owner and the City that
locks in specific development standards, infrastructure and
public benefits for a project
• Offer long term guidance and clarity for complex projects by
detailing all key aspects of a project
• Tool when a developer is requesting consideration beyond land
use / zoning

Questions?

Regulatory Topics For Discussion

Potential Code Topics to Review
• Topics identified from TAC, Mayor & Council, staff, and other
jurisdictions
• Guide draft code for large-scale data centers in Tucson
• Working document
• For discussion, not prescriptive
• Ordered by TAC feedback importance
• Final decisions depend on TAC input, Mayor & Council, and staff

Topic 1: Data Center Definition
•
What are the key
components we want to
include?
•
Should we have a size
threshold?
•
Do we want to include
specific computing
activities such as AI or
blockchain?
•
Tiered Subclass / small
scale data centers?
•
Exclude anything?
Definition from Zoning Administrator’s Determination:
A facility, or a portion of a facility, whose principal use is to store and manage
computer systems, servers, networking equipment, and components related to
digital data operations. These operations include the storage, processing, and
distribution of digital information and may encompass activities related to artificial
intelligence,
blockchain
technology,
cryptocurrency
mining,
computational
modeling,
weather
modeling,
and
genome
sequencing,
among
other
computationally intensive applications.
The facility typically houses networked computer systems and telecommunications
equipment used for remote storage, processing, and distribution of data. It also
includes related infrastructure, office space, and staff areas necessary to support
digital data operations. This associated infrastructure can include air handlers,
power generators, water cooling and storage facilities, and utility substations to
support sustained operations.
A facility is generally not considered a data center if 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.

Topic 2: Permitted Zoning
• I-1 – Light Industrial Zone
• I-2 – Heavy Industrial Zone
• PAD – Planned Area Development
• PCD – Planned Community
Development

Topic 3: Public Notice Process
• Mayor and Council Special Exceptions
require that all property owners within a
400-foot radius of the site be notified by
mail of the proposed change, and that a
neighborhood meeting be held
• For the TAC’s consideration:
• Potential larger notice area than the 400’
standard due to location in less populated
areas and broader impact
• Citywide Neighborhood Association notice
instead of existing one mile standard

Topic 4: Development Standards for Further
Discussion
• Topics provided as discussion points for the TAC
• Some may be included in the proposed code, others may not
• Aim to guide discussion, clarify issues, and support code
development
• Generally ordered based on TAC feedback from the previous
meeting – with some overlap

Summary of Rankings from Previous TAC Meeting
0
5
10
15
20
25
30
Design Features
Vibration
Screening
Design / Aesthetics
Glare
generator operation
Wildlife Amenities
Heat
Location / Setback
Noise
air quality
Energy
Water
Most Important Regulations and Standards to Include in Code

Topic 4.1 - Energy Consumption and Sourcing
•
Must demonstrate access to adequate energy
supply.
•
Provisions for on-site energy generation.
•
Additional questions from TAC:
• Can we require the facilities to have power loss ride-
through capabilities so they switch to backup
generation less often? Or do we need to get at this via
a limit on how often they can use their backup
generators?
• Is it permissible to require some facility classes to
bring their own energy via power purchase
agreements? This would also subject to FERC and ACC
regulations, but I am curious about the limits of our
zoning regulations.
Source: New.abb.com
Source: Siliconranch.com

Topic 4.2 - Water Use and Sourcing
• Must demonstrate access to adequate
water supply.
• Can the PAD (or Mayor and Council Special
Exception) condition for Water
• Additional question from TAC:
• Conservation as proposed here also include
water use for energy production? A first
question is if this is permissible via zoning
regulations, then we could figure out how to
calculate energy use for the facility specifically.
Source: Jetcool.com
Source: gaytucson.com

Additional Reference

1
City of Tucson Planning and Development Services
Data Center UDC Technical Advisory Committee - Meeting #3
Monday, January 12, 2026 | 4-6pm
Public Works Building, Basement Conference Room C (201 N. Stone Ave)

Meeting Summary

Participants – see end

Discussion on Regulatory Topics
The group continued discussion from the previous meeting, moving through the potential regulatory
topics shown in the meeting presentation. In addition to providing feedback during discussion, members
were given the opportunity to share written feedback on each topic. These notes include both meeting
discussion (in-person and virtual) and written feedback, which has been incorporated in the appropriate
topical section. Planning and Development Services (PDSD) staff responses to questions are in sub-
bullets.

Topic 4.2: Water Use and Sourcing
This topic was also discussed in the last TAC meeting. At that time, members shared that it is important
this is consistent with the City’s Climate Action Plan, and other sustainability goals.

Discussion
•
What is actually allowable within zoning? Can we put limits on how much water a data center
can consume?
o PDSD clarified that this will be primarily addressed through the Large Quantity Water
Users (LQWU) Ordinance. There is limited authority to regulate water use through
zoning.
•
It appears that there is really no approach to zoning code that can address water use and
sourcing, so we need to ensure that there is a municipal code to address this issue.
•
If we aren’t able to regulate the water and energy use through zoning, perhaps we need to try
and create the code such that hyperscale data centers will not be permittable, even though
there are arguments to allow them for economic development.
o The request from Mayor and Council to PSDS is to establish standards. What we’ve seen
in Pima County and Marana is if we simply prohibit them, we won’t have a say over how
they happen. The concern is that they would start to proliferate at the boundary.
•
Focus on responsible water use, not just access to adequate water. We need to ensure a direct
reference to the Large Quantity Water Users Ordinance.
•
We should add a net-zero, or net-positive, water policy. All water use needs to be offset in the
Tucson basin with wet water strategies.

Topic 4.3:Noise Attenuation / Vibration
In other places data centers are being built closer to residential areas than we might see here, but in the
desert sound often travels faster. Noise was discussed in the recent Marana meeting, and it is included
in some of the other example codes.

Decibel limits

2
•
Clarification that the limit would be a “not to exceed,” rather than an average. Examples in
other codes are 55-65 decibel limits.
•
It would be prudent to align with approaches already implemented by other municipalities such
as the City of Mesa and the City of Phoenix. Specifically, if a data center is located within
approximately 400 feet of a residential area, the allowable decibel levels at the property
boundary should match those of the adjacent residential zoning. If the data center is not within
close proximity to residential uses, the allowable noise levels should instead align with those of
the surrounding adjacent uses. An approach like this would provide clarity while remaining
consistent with existing municipal standards.
•
Noise regulations should take into account wildlife corridors.

Landscaping
•
The City of Chandler used sound walls.

Topic: 4.4 Generator Regulation / Air Quality
Other ordinances have specified Tier 4 generators in their zoning. This doesn’t regulate the emissions as
much as they type of equipment that can be used.

Overall comments
•
Requiring high-efficiency generators with low-emission profiles is an excellent approach.
•
We need emissions or air quality regulations that do not prohibit realistic data center
development within the zone, but do require low or net-zero emissions/newer technology.
Technology changes, so it seems better to set air quality/emissions limits rather than prescribe
specific technology.

Energy use during power outages
•
Mandate battery use during an outage for the time it takes to re-connect to the grid. If a data
center thinks there will be an outage they generally want to switch to a diesel generator.
Sometimes they will use batteries for the time it takes to get diesel generators up and running.
But if they could use batteries for the duration of the outage, that would be better (although
longer outages may still require diesel generators).
•
Battery backup should kick in first, before generators, even though it may be more costly.
•
The average outages are typically pretty short. Generally speaking, TEP can respond within an
hour to an outage.
•
Could we find a way to match generator use to power outages, in terms of timing?

Switching to generators during times of high grid stress
•
There may be an opportunity to think about having data centers run on generators during the
few hours each year when the grid is really stressed. But this would only make sense if it was
natural gas, not diesel, due to emissions.
•
This practice was used in the Phoenix area for a period of time but has since been rescinded,
except in cases where natural gas generators are used.
•
Could we think about requiring battery power for times when the grid is really stressed?
•
Battery use is technically feasible for a hyperscale data center to use for 1-2 hours at a time.

Enclosing generators

3
•
Should generators be enclosed?
•
The site on Irvington has generators in buildings, and includes noise mitigation on the exhaust
side. They also go through EPA and PDEQ review.
•
Generators are typically in a “gen house” or dampening enclosure, not out in the open.

Use of natural gas
•
If natural gas generators are permitted within the Tucson area, there may need to be additional
regulatory considerations specific to their use.
•
Natural gas will be a lot more emissions friendly. Regionally there are some limitations to this,
currently. But that is getting addressed right now. There will be capacity in the future. We
probably don’t want to write the code to limit natural gas as an option.
•
Most generator sets are dual fuel for these purposes, with diesel on site as a third backup
source of "power."

Generator maintenance
•
Allowing Uninterruptible Power Supply (UPS), which could include an engine
gen/set (natural gas, diesel fuel, or both), battery backup, and even ultra/supercapacitors, to
be maintained only Monday-Friday could be difficult. Perhaps we could distinguish
between “periodic or regular” maintenance involving running/testing the unit from Monday-
Friday 9am-5pm and “emergency” maintenance specifically to address immediate reliability
issues with the UPS allowable 24/7/365.
o PDSD noted we would need clarity about what constitutes an emergency. We may not
want to micro-manage exactly when to turn on/off. What we really want to prohibit is
to decide generators are cheaper, and run them all the time.
o Several members noted that this would not be likely as the grid is more stable than
generators and the preferred energy source.

Co-located energy production / onsite generation
•
There are gen set options that could be used full-time, as opposed to backup. Is this code meant
to cover just the data center, or the data center and onsite generation?
o PDSD hasn’t seen other ordinances with these requirements, but it would likely be
encouraged. Seems there could be the possibility for some onsite generation.
•
A 500 MW hyperscale center would require a huge on-site powerplant.
•
Small nuclear was briefly discussed but generally felt to not yet be a viable or relevant option.
•
If there was onsite generation, would it be zoned as a power plant?
o PDSD noted that Utility Generation Ise isn’t permitted by right in any zone, but you can
use a PAD for them. Depending on how much of the square footage it is, it may be an
ancillary use, or a primary use.
•
We should incentivize or encourage onsite renewable generation

Topic 4.5: Setbacks / Design Features
Overall comments
•
The current language appears appropriate and well-structured, and similar to other
municipalities.

Landscaping

4
•
This should include water harvesting and green infrastructure. There are other commercial
requirements for water harvesting that should perhaps be referenced.
o PDSD noted that we could perhaps include a provision that this must comply with the
section onr rainwater harvesting.
o PDSD clarified that the landscaping would be low water use. There are approved plant
lists and other policies that will help establish this.
•
Desert trees should be required.

Setbacks
•
We should consider more than a 400’ residential setback.
o PDSD noted that 400’ is pretty consistent with other ordinances, but they can look for
examples of more than this. They also wondered if this setback should be required if the
adjacent land use is industrial.
•
All of the State Land will be re-zoned to SR. To find anything on the southeast side of town that
is a 400’ setback from that would be challenging.
•
Perhaps you could look at a spatial analysis of the zoning map to see the impact if it was, for
example, 500’; would it be functionally impossible?
•
If setbacks are primarily driven by noise concerns, are there any incentives for a smaller setback
for projects that include more noise attenuation?
o PDSD didn’t know of other examples of this. It could be feasible, but challenging to
document. This would be somewhat similar to odor mitigation for marijuana cultivation,
which is really challenging. It depends on many factors. They could have mitigation for
noise, but it might not make a difference.
•
Look at examples in Mesa that are close to residential (the Eastmark area where there is a lot of
hyperscale data centers on the north end of the neighborhood).
•
Could we explore tiered setbacks related to the size of the facility?
•
Include setbacks from critical watershed areas. No development within the 500 year floodplain
or in riparian areas.
o PDSD noted that the challenge with that would be in treating this use differently to
other uses (like warehouses) that don’t have this requirement. It can be explored,
however.
•
Typically we wouldn’t want to see setbacks expand without a good rationale.
•
Ensure that natural open space and riparian areas are considered in “other noise sensitive uses.”

Parking
•
There should be no parking requirements so they are not overparked.
•
Data centers typically have only about 10 people on staff in a shift, so not much parking is
required.

Decommissioning of the site
•
Should this be in the zoning, or the development agreement?
•
We want to make sure we can re-use the building and not tear it down. And we do want to do
deconstruction vs. demolition if it comes to this.
•
Decommissioning plan requirements should include site remediation re: environmental
concerns.

ANSI Standards

5
These are trade group standards for data centers. The City doesn’t have access to them, however.
•
Applying these standards is a good idea. The City Commission on Climate, Energy and
Sustainability (CCES) has looked into these with regards to data centers. The Engineering school
at UA may have a copy.

Co-location incentives
•
Avoid duplicative setbacks for co-located projects.
•
Maximizing co-location incentives would be smart.

Topic 4.6: Heat impacts
•
Recommend considering mitigation strategies such as heat-reflective or heat-absorbent
materials. There have been several trials in the Phoenix area using reflective (white) coatings on
streets to reduce urban heat-island effects. It is already common practice for data centers to
utilize white or reflective roofing systems to minimize heat gain and reduce cooling loads.
Establishing a reasonable baseline requirement here would be sufficient.
•
Data centers don’t like heat.
•
There could be improvements in how Tucson mitigates heat. This could include paving
materials/colors, reflective materials, cool parking lots, cool pavement, additional landscaping
with native plants, reduction of asphalt and hardscapes, and use of permeable paving and
surfaces that don’t absorb as much heat.
o PDSD are working on Low Impact Development standards now, and changes to the
plant list. This objective fits well within this exercise. If things come up here that are
related to these kinds of larger scale changes, we need to make sure it gets incorporated
in the right way. Or sometimes individual codes can be treated as test cases.
•
How do zoning requirements evolve with the times if we are always stuck trying to match old
codes?
o PDSD noted that data centers is a new use, so we want to address these things.
Generally larger changes are made over time.
•
Can we require covering parking lots with solar panels?
•
In the grand scheme of what these data centers are building, this is so cheap for them. We
should have good standards. Should we look at albedo limits?
o PDSD noted that the ADU (Auxiliary Dwelling Unit) code used albedo limits. These may
need to get changed in the building codes.
•
We should look into the building code change. If they are really large why not kick it off with
standards that are good and that they can meet?

Topic 4.7: Screening
•
Recommend looking at this as an opportunity to help cool and shade neighboring amenities
(sidewalks, bike lanes, public spaces), using native shade trees and cooling native shrubs; plants
with more evaporative cooling potential.
•
Make sure screening is used as a way to help offset the heat island affect.
•
The screening requirements outlined appear appropriate. Most data centers are designed to
prevent open or casual access to the building for security reasons. As long as the screening
requirements align with the acoustic mitigation standards, this section should function well.

Topic 4.8: Wildlife Amenities

6
•
Ensure that existing riparian areas are protected if they are on the site.
•
Protect wildlife amenities when a property is located near designated wildlife areas. It would be
reasonable to require preservation or mitigation measures when such adjacency exists.
•
We don’t want to disturb existing water flows. Right now the zoning doesn’t necessarily protect
against this.
•
Pima County’s Conservation Land System (CLS) was included the City’s General Plan, so the City
is supposed to consider these lands. This should apply to a data center proposal as well. It hasn’t
yet been used by the City to-date, but we have to try it first. It covers larger washes in the city.
The CLS is part of policy, not ordinance. We want language that makes clear that adhering to the
CLS is a requirement for an application.
o PDSD confirmed that this is a policy in the General Plan, and this is used for entitlements
and re-zoning. There is the guidance to adhere to this, and more guidance is being
developed.
•
Protect existing arroyos and washes, as well as riparian areas and the 500 year floodplain.
•
We often see the developers thinking it’s good to put a path on a wash. We completely
disagree.

Topic 4.9: Glare
•
Most data centers are architecturally simple structures with non-reflective exterior finishes and
limited glazing. As such, glare issues are generally minimal. Any glazing that is included would
already be subject to existing codes related to window reflectivity, airport proximity, and similar
concerns. Additional data-center-specific requirements are not necessary here.

Topic 4.10: Design and aesthetics
Murals and general aesthetics
•
It would be great if murals could be required.
•
Love the mural idea to give artists more jobs.
•
The proposed language is pretty common. One consideration is that if a minimum number of
design features or amenities is specified (for example, five items), most projects will deliver only
the minimum required to control costs. Instead it would be better to be judicious in defining
both the quantity and type of required design elements, as this will directly influence project
outcomes.

Undergrounding utility infrastructure
•
Undergrounding transmission to the site is more difficult. If this is a concern, it would be better
for TEP to work with the City and the user to site the substation in the best possible location,
away from other customers and uses. Undergrounding transmission to the site would likely
require additional switch yards. Underground for their on-site distribution is possible.
•
Wherever feasible, I am strongly in favor of undergrounding electrical infrastructure. This
improves physical security and reduces exposure to weather-related impacts. Based on my
understanding of approaches used in other municipalities (such as Mesa), very high-voltage
infrastructure (e.g., approximately 230 kV) typically remains above ground. Mid-range voltages
are often left to the discretion of the utility provider and the operator, while lower-voltage
infrastructure is generally installed underground
•
Underground onsite is preferred.

7
Other comments
o It would be good if these developments could help advance planned bike/pedestrian/bus
infrastructure. For example, if vegetative screening is on the perimeter of sites that are adjacent
to public spaces, there could be a benefit to this mobility infrastructure.
o PDSD noted that benefits to open space and public amenities could be part of a
development agreement.

Topic: Other Items for Consideration
•
Is a new zone a potential outcome of this?
o The current discussion is to put this in existing zone(s). But the Mayor and Council
Special Exception process allows for a rigorous review, within existing zones.
•
Is there an opportunity to coordinate with TEP on sites?
o TEP is already part of the rezoning review process. Most potential data centers that
have approached TEP have all been within the proximity of the transmission system.
•
We should be proactive about where the big power users are in relation to the supply so that it
is strategic and not ad hoc.
•
The two critical areas of consideration for a hyperscale data are energy and water, but neither
are addressed in the zoning code. Assuming the city does not wish to prevent their siting within
the city, it seems we should designate a preferred area remote from residential neighborhoods
and commercial sectors (southeast quadrant) where co-location incentives would be
meaningful.
•
One item that has not been discussed in detail is building height. If this is not addressed
elsewhere in the zoning or development code, it may be worth considering explicit height
limitations. Even within I-1 or I-2 zoning, height restrictions can help reduce potential impacts
when facilities are located near residential areas.
•
We need to ensure the proposed regulations use hard, enforceable rules instead of fees. Trillion
dollar tech companies would have no trouble paying fees for violating our regulations, so the
rules must be strict.
•
AI Safety should be mentioned as an item for Mayor and Council to consider adding to
development agreements on a discretionary case-by-case basis. This should also include a
reference to the legal precedent from California law, and an explanation of what AI safety
means.

Next Steps
•
Share survey to get TAC feedback on community meetings - January
•
Develop outline of proposed code/standards - January 26, 2026
•
Schedule and Plan Outreach Meetings - Week of January 26th
•
Send outline to TAC with a survey for feedback - Week of January 26th
•
Hold Outreach Meetings (1 in-person, 2 virtual) - February 2026
•
Complete Draft Ordinance Language - February 2026
•
4th TAC Meeting - Late February 2026
•
Planning Commission Study Session - March 2026
•
Planning Commission Public Hearing - April 2026
•
Mayor and Council Consideration - May 2026
Participants

8
Technical Advisory Committee
*virtual participation
Name
Area of Expertise
Organization/Affiliation
Lisa Shipek
Water / environmental
Watershed Management Group
Kate Hotten
Environmental
The Coalition for Sonoran Desert
Protection
Ed Hendel*
Water/land use
Citizen's Water Advisory Committee
Chris Lindsey
Power systems and renewable energy Tucson Electric Power
Chris Dougherty*
Data center
Ark Data Center
Shawn Bluebaum*
Infrastructure and construction
Sundt
Jason Makansi*
Land use regulations
Planning Commission liaison
Ryan Gruver*
Data center operations
Banner Health - IT Director
Adria Brooks
Power systems and renewable energy
Grid Strategies, Director of
Transmission Planning
Dan Stormont
Environmental
Commission on Climate, Energy &
Sustainability
Remy Franklin
Energy Resources
Interwest Energy Alliance

Staff Technical Support (City of Tucson unless otherwise noted)
Name
Position/Role
Area of Expertise
Fatima Luna*
Chief Resilience Officer
Resilience
Mike Czechowski
Economic Initiatives
Economic development
Scott Schladweiler
Tucson Water
Water
Michael Catanzaro* COT Energy Manager
Energy
Savannah Martinez COT Emergency Manager
Emergency management
Anita McNamara*
Pima County Development Services
Department
Land use
Brad Borman*
City Attorney's Office
Legal
Chris Avery
City Attorney's Office
Legal
Stacy Balstad
Mayor Ward Office Staff – Ward 6
Elected officials

Planning and Development Services Team
Name
Position/Role
Area of Expertise
Daniel Bursuck
Planning and Development Services Planning Administrator
Nicholas Martell
Planning and Development Services Section Manager
Carver Struve
Planning and Development Services Principal Planner, and Primary POC
Cesar Acosta
Planning and Development Services Principal Planner
Ian Wan
Planning and Development Services Lead Planner

Facilitation
Southwest Decision Resources – Tahnee Robertson and Colleen Whitaker

Technical Advisory Committee Meeting
Large-Scale Data Centers
Meeting 3
January 12, 2026

Meeting Overview
• Welcome and Introductions
• Continued Potential Code
Topics Discussion
• Next Steps
Source: Shutterstock.com

Wi-Fi Access
Username: Pima-Patron
Password: PatronWiFi2020 (case sensitive)

Continued Regulatory Topics For Discussion

Topic 4.3 - Noise Attenuation / Vibration
•
Baseline noise study
•
Noise contour exhibit
•
Decibel limits for sound emanating from
property
•
Increased landscaping and site requirements
for sound absorption including the installation
of berms and walls
•
Post construction compliance / monitoring /
liaison
Source: Data Center Noise Study for Prince William, Fauquier, and King George Counties
and the Town of Warrenton
15 Minutes

Topic 4.4 - Generator Regulation / Air Quality
•
Tier IV or newer generators (diesel
generators with advanced exhaust treatment
systems that achieve near zero emissions)
•
Generator operation only during emergency
situations, or for preventative maintenance
•
Limit maintenance operations to 9-5,
Mondays through Fridays
•
Sound blocking along generators
•
Hazardous materials storage for generator
fuel
Source:.Forconstructionpros.com
10 Minutes

Topic 4.5 - Setbacks / Design Features
•
Minimum setback 400-feet from residential
zoning or other noise sensitive uses
•
Minimum setback 400-feet from mixed use
zoning
•
Potential setback of 200-feet from any other
zoning
•
Mechanical equipment set back and screened
by a solid screen wall
•
Acoustical screening
•
Additional landscape or other screening
requirements for noise mitigation
Source: Businessinsider.com
Source: NAIOP.org
15 Minutes

Topic 4.5 - Setbacks / Design Features
•
Define minimum parking ratios
•
Potential adaptive reuse or
decommissioning
• Adequate space for expansion of parking
to accommodate a different use such as
manufacturing
•
ANSI/BICSI 002-2024 Standards
•
Colocation incentives
•
Increased detail requirements for project
phasing
Source: www.Roofscreen.com
15 Minutes - Continued

Topic 4.6 - Heat Impacts
• Landscaping and shaded paths
• Open space requirements for
heat island mitigation and
wildlife habitat
• Cool roof requirements (if
feasible, generally addressed
through building code)
Source: Laddkeith.com
10 Minutes

Topic 4.7 - Screening
• Berms
• Walls
• Additional landscaping
Source: Iron Mountain’s AZP-1 data center in Phoenix, Arizona. Photo taken on Feb. 19, 2025 by Maya Chari
10 Minutes

Topic 4.8 - Wildlife Amenities
• Preservation of open space or
habitat areas
• Preservation of wildlife
corridors or crossings
Source: Pima Association of Governments
10 Minutes

Topic 4.9 - Glare
• Existing Airport Hazard District
and Industrial Use Group language
“any activity producing intense
glare or heat shall not be
performed in such a manner as to
create a nuisance.
• Any additional glare
considerations
Source: American Solar Energy Society
5 Minutes

Topic 4.10 - Design and Aesthetics
•
Requirements for Murals
•
Requirements for Façade
treatments
•
Requirements for
underground utilities
Source: Slate.com
5 Minutes

Other Items for Consideration
• AI Safety
• Additional items as identified

Updated Process and Timeline
•
3rd TAC Meeting - January 12, 2026
•
Develop outline of proposed code/standards - January 26, 2026
•
Schedule and Plan Outreach Meetings - Week of January 26th
•
Send outline to TAC / Survey for Feedback - Week of January 26th
•
Hold Outreach Meetings (1 in-person, 2 virtual) - February 2026
•
Complete Draft Ordinance Language - February 2026
•
4th TAC Meeting - Late February 2026
•
Planning Commission Study Session - March 2026
•
Planning Commission Public Hearing - April 2026
•
Mayor and Council Consideration - May 2026

Additional Reference

1
City of Tucson Planning and Development Services
Data Center UDC Technical Advisory Committee - Meeting #4
March 9,2026 | 4-6pm| PDSD Office, 4th Floor

~DRAFT Meeting Summary~

This document includes a summary of the meeting discussion. Throughout Planning and Development
Services (PDSD) staff responses to TAC questions are in sub-bullets and italics.

Participants – see end

Overview of Proposed Large-Scale Data Center Standards
PDSD shared a presentation outlining the proposed standards which were shared with the public in the
recent round of community meetings. Summary of feedback received and PDSD proposed changes follow
in subsequent sessions.

Overview of Community Meetings and Feedback Received
•
Four community meetings were held since the last TAC meeting - two in-person, and two virtual.
Each had between 45-80 participants.
•
The in-person sessions were a hybrid open house with presentation. The virtual meetings had
presentation and discussion in breakout rooms. Surveys were included in both: online and
hardcopy.
•
PDSD has received over 550 unique comments. This doesn’t yet include the chat comments from
the virtual meetings, which will be added. Everything will be posted on the website soon. They
have also developed, and will continue to update, the FAQ document.
•
The main comment heard was outright opposition to data centers. It’s difficult to have a
conversation about regulation when this is the primary sentiment.
•
Much of the additional concerns focused on water scarcity, impacts on utility bills, existential
concerns about AI/technology/privacy, noise, air pollution, equity and accountability.

Reflection from TAC members who attended meetings:
•
Not sure it was clear to people that this process is not the place to disallow data centers. That is
not the task of this committee. This needs to be made very clear upfront to Mayor and Council
when sharing back.
•
People seemed to think that zoning could do more than it can (e.g. define energy mix). Not sure
how to communicate this better – people don’t understand what zoning can and can’t do.
•
A question around light pollution was raised – while we have glare requirements, it would be good
to address light pollution as well.
o There is a reference to existing lighting standards, but the outdoor lighting code could also
be referenced specifically.
•
Seems like many people just want the City to say no to data centers. Maybe we could outline what
would happen if we do nothing and make no changes to the current situation? What would be
the impacts? Does it make it easier to build data centers?
o Data centers are currently easier to build than they would be under the proposed
standards, as there are essentially no guidance or standards now. The team tried to show
this in the meetings, but perhaps it needs to be made clearer. It may be helpful to highlight

2
that without any changes, people will only be notified of proposed data centers within 400
feet, and neighborhood associations within one mile.
o There are a number of concerns with prohibiting data centers outright – right now we
don’t prohibit anything in the zoning code. Even if we did this, it could probably still be
written into a zoning code. We may need to be clearer about this.
•
PDSD did a good job of outlining the process, but it still may not be clear to the public that this
process does not equal an automatic approval of a data center. We need to emphasize the role
of public review and that this is not an attempt to streamline the data center review process.
•
The two things that the public are most concerned with (water, energy) are the two we can do
the least about in this process. Noise, however, we can address. We need to have a better
understanding of how the emergency equipment (generators, fly wheels, etc.) will operate in the
real world.

Potential changes to proposed standards for Data Centers UDC Amendment
PDSD reviewed the proposed changes currently being considered based on community feedback. TAC
members shared their thoughts on these, as well as their own feedback on the proposed standards.

Large-Scale Data Center Definition
Current proposal: 50,000 sq ft. (gross floor area)
Feedback: There was some input that the size threshold should be lowered.

•
Probably basing it on footprint alone is not sensible. Maybe it should be based on energy and
water impacts (even though we can’t regulate these directly). A large data center requires a lot of
energy and water.
o This has been considered. The biggest challenge is regulating this. A proposal could come
in under a certain level but then ramp up their energy use later. How would we account
for this?
•
How does 50,000 sq. ft. compare to what we consider a large warehouse?
o This would be a moderate warehouse. The Amazon building off of Kolb is about ten times
this size.
o The goal is to try and find a proxy for energy to make it something we can regulate. The
industry uses energy use or acres of land size (which also doesn’t make a lot of sense here).
•
This could perhaps be addressed as an “and/or” with the definition being triggered by the lesser
of the two.
•
There’s no harm in dropping the square footage a bit, perhaps to a current data center size. Also
recommend getting rid of the “contiguous” component of the definition.
•
Many of these centers tend to have pretty big conference rooms, so we wouldn’t want to make
the threshold too small.
•
Larger businesses/organizations have large server rooms (e.g. U of A). If there is a server room in
an office building that is 51,000 sq. ft does this mean it is a data center?
o We could add language about the principal use of the space.
•
This is just the definition, not the regulation. Why can’t we include energy consumption?
o The definition dictates what qualifies for the regulations, so we do need to be careful.
There may be a way to work in the and/or approach to get at energy consumption.
•
This industry is looking at racks that are getting bigger and bigger. It would be advisable to use
the “and/or” approach so that power consumption could be a factor.

Enhanced public notice
Current proposal: Increase notice area to ½ mile and all Neighborhood Associations within 2 miles
Feedback: the notice boundary isn’t big enough; renters should be noticed in addition to property owners.

•
The noticing distance makes sense. There should be a general public notice as well.
•
Neighborhood Association mailings go to all addresses, regardless of whether it is a renter or
owner. Why can’t we do this approach?
•
All residents should be noticed; the City should figure out how to get the addresses.
o This requirement to notice owners is reflective of the fact that it is a potential land use
change to a site. Part of the issue with using addresses is that the accessor data is not
great for multi-family buildings. There doesn’t seem to be a good way to get all the
accurate addresses.
•
Is there a public website/repository of all applications received, and if not, can we develop one?
o In the past there was a system that sent out a notice when an application that is part of a
discretionary process was received. There is a development activity map with active
permits and processes. There are ways to make sure that the information is available.
•
During the community meetings I heard a lot about environmental racism related to where the I-
2 zones are located. This is somewhat of a chicken and egg issue. One way to address this could
be to remove I-2 but still include the review process.
o Most of the I-2 is not near residential. Someone could always re-zone their I-2 property to
a PAD or PCD. A better way to address this could be to increase the setback to ¼ mile. We
need to look at how this works when we setback from a residential zone in the county.
•
Can we simply carve out the residential areas of I-2 zones?
o For the most part I-2 doesn’t have residential (it’s not allowed). The zoning was
determined in the 1940’s, but there are a couple areas within the county that have
developed as residential since that time.

Setbacks
Current proposal: Setback 200’ to commercial areas and 400’ to residential areas.
Feedback: the setbacks need to be increased. PDSD is considering ¼ mile setback from residential and 600’
from commercial.
•
Increased setbacks make sense. If that takes care of the I-2 zone issue, that’s good.
•
This is a large setback.
o Guidance from Loudon County, Virginia is that is dealing with data centers, is that 500-
1,000 ft at a minimum is needed. This may overshoot that a little, but that might be good.
It does help with noise issues, and some heat issues. A professor working on this type of
heat tells us that 400-500’ is where the heat starts to dissipate.

Noise
Current proposal: a number of measures, including decibel limits at property level, baseline studies and
sound walls.
Feedback: concerns about noise impacts, including low frequency noise

•
We haven’t defined quantitatively what the decibel limits should be; this should be included. In
the community meetings people also talked about duration and spatial attenuation. We should
add volume, frequency, duration and attenuation into the baseline study.

4
o There are some existing standards in the noise ordinance; we need to see if this includes
duration and spatial attenuation.
•
Low frequency noise is hard to mitigate because it travels a long way. How can we deal with this?
o The additional setbacks are an attempt to address this, as well as the noise study. We may
need to include frequency specifically in this. There are also other mitigation measures
such as berms.
o Note that berms are not effective for low frequency noise, as it travels straight through
them.
•
When wind turbines first got going, a big issue with neighborhoods was the hum, in addition to
the strobe effect. The hum could be heard for miles. We should learn more about the potential
for this, so that it’s not an unintended consequence.
o Were there things that that industry did to try to mitigate this? (Jason M offered to share
some research on this).

Backup Power / Generator Use
Current proposal: A number of measures, including generator use only during emergencies and
maintenance; battery backup used first, non-emergency maintenance limited to weekdays 9am-5pm.

Feedback: What constitutes an emergency? Concerns about air pollution and noise. TAC Members asked
if battery backups could be used for community benefit?

•
The RICE generators at the Sundt generating station may be our most similar example. What are
the requirements for those back-up generators?
o There are not specific regulations for these back-up generators - this would be part of the
City noise ordinance, or air quality regulation through Pima County. We are considering
more stringent requirements here because of the scale. There are restrictions for back-up
generators used in cell towers, but that scale is much smaller. We’ve seen this is similar to
what has been written into codes elsewhere.
o The member from TEP didn’t think there were operational restrictions on the RICE units
outside of air permits. They are designed to run and operate as needed. This would be a
different application – the backup generators would be used when there is a grid issue.
•
Someone in the community meeting thought that the 9-5 windows isn’t sufficient for
maintenance.
•
For TEP, maintenance would mean we take the generator offline. The restriction to business hours
makes a lot of sense, but we don’t know how frequently they are likely to be doing this. Would
we want to see them having this more scheduled? How do you do it when there are 100
generators?
•
Would they not need to tell TEP when they plan to do the maintenance?
o The member from TEP shared that that would certainly be preferred.
•
The number of batteries these centers plan to have onsite is enormous. They are also talking
about other backup (flywheels, ultra capacitors). The load fluctuations inside these facilities is on
a scale we have not seen before in the energy system. The backup systems will be massive and
varied, and they may have equipment we haven’t discussed.
•
In the industry, batteries are used as bump to get us to the generators, batteries are not a multi-
hour approach. Battery Energy Storage Systems (BESS) are starting to become popular for load
shifting during peak summer hours. That is still being adopted in the industry. For a flywheel, this
would be about two minutes.

5
•
At the risk of going against some of the public feedback, if there is a lot of capacity, that is where
community benefit would come into play. We could load shed the data center. If a data center
had an ability to ramp up backup generator, or other resources, for the period of time of a grid
emergency, this would be beneficial to the grid and to the community.
•
Being able to run the generators during peak hours will make it less costly for residents. But these
are diesel generators, so it’s bad for emissions and noise. The definition of emergency could
include a way to identify when TEP anticipates having capacity issues.
•
When there is a short outage on grid, having them be able to subsist an hour will be important
for noise and carbon emissions. We should push for two hours of battery. We could also say “low
noise, carbon free” power so it doesn’t have to be batteries if there is another solution.
•
Upsizing the batteries could help TEP as well.
•
One facility discussed in a recent related meeting was planning to have 1000 MW of batteries
backing up 1000 MW of generation.
•
The way we define “emergency” is important. NERC (North American Electric Reliability Corp) has
a definition we could align with.

Energy Generation
Should we include potential clean energy requirements through offsets, or Development Agreements?

•
The proposed energy use mix is a ton of work, although it is a sign of the commitment to improve.
•
We should push the limits of what we’re allowed to do with this. This wouldn’t be onsite; they
would have to invest in it offsite.
o It’s unclear how much we can do through zoning and/or a development agreement. How
do we ensure we align the development agreement with community benefits and needs?
•
There isn’t anything about community benefit agreements in the proposed regulations, will that
be added?
o It’s not appropriate for the zoning code, but it would be an accompanying resource moving
forward.
•
Would this be aligned with the Climate Action Plan, Plan Tucson, etc. Note that the ACC has
changed their direction.
o The intent is that it would align with all the existing policy guidance. We want creative
solutions (example of a data center in Nevada utilizing geothermal from Utah). There is
quite a bit of money to do these things, how do we take advantage of this with the
proposal?
•
It’s difficult to envision solar panels getting them enough power. It could be tough to meet these
requirements on a near-term basis. This might be a longer-term strategy.

Water quality regulation
How we should include thermal and chemical impacts on water quality. Who regulates this What else
should be included?
•
Thermal is likely not a concern, as we’re not discharging into the ocean. The chemical impacts did
come up with Project Blue (in that case it is county sewage treatment). We should include PDEQ
standards and what the county can accept in wastewater treatment.
•
Has PDEQ been involved in this conversation, and can we see their comments?
o They have been involved, and their comments were mostly specific to what they regulate.
See past TAC meeting notes for details.

6
o PDEQ (Scott DiBiase) – We did share comments early on. In terms of air quality permits
and generators, there were some considerations about the timing of backup maintenance
during peak ozone season. As for the scale – we haven’t gone this far in a relationship
with any data centers, so we don’t know the likely scale of any potential backup
generators. In terms of water quality regulations – PDEQ’s role is pretty limited. We have
regulations for public water systems – this is tied into Pima County Wastewater.

•
The foam used in fire extinguishers includes PFASs. We need a plan for what happens if there is a
fire – where would the chemical flow, and how do we keep it from getting into waterways?
o Another TAC member noted that banning PFAS from fire-fighting foam is currently being
debated in the state legislature.
•
There may also be PFAS coating their cooling pipes. PDEQ should be aware of this, and there are
standards.
•
Can we require closed-loop cooling and air-cooled condensers?
o What happens if there is another technology that comes out that is even better? How do
we say this is what we want now, but still allow for better technology in the future?
o The EPA used to use the term “best available control technology,” or something similar.
•
We should prohibit open loop cooling.
•
In terms of water quality, even with closed loop you eventually have to discharge some of the
liquid, so there is contaminated water there.

Additional considerations and recommendations
PDSD asked what else the TAC thinks may be missing. These comments have been integrated into the
relevant topic above, with those unrelated to the above topics included here.
•
Public review process: Suggest two or more neighborhood meetings, not only one. It would also
be helpful to break up the Mayor and Council meetings so that the approval can’t happen in the
first meeting, to give time if people are just learning about this? Discussion/review in one meeting
and then decision in a subsequent next meeting.
•
We should have a requirement to create community benefit plans. Or maybe we can only suggest
this?
o So far, the guidance is that this can only be suggested.
•
Landscaping – require native plants and disallow the use of any well/utility water for landscaping
(all water used for landscaping should be caught onsite). Choose plants that have passive cooling
to address heat islands.
•
Total water use should be disclosed, along with energy usage.
•
Water use should not just be onsite, but consider scope two (indirect water use).
•
Compliance – the applicant should be responsible for continuous environmental monitoring on
their boundaries (ambient temp, air quality, etc.). This would provide a lot of information about
when they are using their backup generators. Is this type of data something that the city has
experience collecting and using? Should it be posted publicly to allow for citizen scientists to get
involved?
•
Compliance reporting – they should self-report, and if they are not in compliance, they should
explain why. We could develop a list of data they have to supply – water use, batter operation,
etc. If the City doesn’t have a standard practice, instead of making this unique to data centers, it
could be suggested to Mayor and Council that we need to find a way to do this type of compliance
reporting and monitoring.
o We could include an element of public posting of data.

7
o PDEQ - there are compliance reporting requirements in regards to air quality. If people
are not abiding by their permit, there are enforcement measures that are followed.
•
In my neighborhood we have seen issues with getting code violations enforced. How would that
work here?
o This is usually complaint driven and done through code enforcement. The water
component is different here, however, because they will report to Tucson Water through
the Large Quantity Water Users ordinance. For zoning violations - without appropriate
reporting, this could be very challenging. The challenge for compliance reporting is that
this is really not done with any other use. More recently there has been some reporting
and monitoring of rainwater harvesting.

Next steps
•
The online survey will be open through March.
•
Mayor and Council would now like to have a study session (likely April 7) for PDSD to brief them
on the work of the TAC, community meetings, and feedback receive. They may direct PDSD to
host more meetings, or make changes.

8
Participants

Technical Advisory Committee Participants
* virtual participation

Name
Area of Expertise
Organization/Affiliation
Lisa Shipek*
Water / environmental
Watershed Management Group
Ed Hendel *
Water/land use
Citizen's Water Advisory Committee
Chris Lindsey
Power systems and renewable energy Tucson Electric Power
Chris Dougherty*
Data center
Ark Data Center
Shawn Blubaum*
Infrastructure and construction
Sundt
Jason Makansi*
Land use regulations
Planning Commission liaison
Ryan Gruver*
Data center operations
Banner Health - IT Director
Darin Gregg*
Large scale data user
USAF Intelligence
Adria Brooks
Power systems and renewable energy Grid Strategies, Dir. of Transmission Planning
Dan Stormont
Environmental
Commission on Climate, Energy & Sustainability
Joe Fico*
Internet Service Provider
Login LLC and COT Contractor

Staff Technical Support (City of Tucson unless otherwise noted)
Name
Position/Role
Area of Expertise
Anita McNamara*
Pima County Development Services Dept.
Land use
Scott DiBiase*
Pima County Dept. of Environmental Quality
Air quality
Brad Borman
City Attorney's Office
Legal
Kristin McRay*
Ward 1
Elected officials
Stacy Balstad*
Ward 2
Elected officials
Teresa Olson*
Ward 4
Elected officials
Manisha Bewtra*
Ward 5
Elected officials
Rae Winch
Ward 6
Elected officials
Eryck Garcia*
Mayor’s Office
Elected officials

Planning and Development Services Team
Name
Position/Role
Area of Expertise
Daniel Bursuck
Planning and Development Services
Planning Administrator
Nicholas Martell
Planning and Development Services
Section Manager
Carver Struve
Planning and Development Services
Principal Planner, and Primary POC
Cesar Acosta
Planning and Development Services
Principal Planner
Ian Wan
Planning and Development Services
Lead Planner
Ina Ronquillo
Planning and Development Services
Public Information Officer

Facilitation: Southwest Decision Resources – Tahnee Robertson, Colleen Whitaker

Technical Advisory Committee Meeting
Large-Scale Data Centers
Meeting 4
March 9, 2026

Meeting Overview
• Welcome and Introductions
• Proposal Overview
• Community Outreach Meetings
• Summary of Feedback Received
• Potential Changes to Proposal
• Next Steps
Source: Shutterstock.com

Proposal Overview

• Permitted as a PAD or PCD as a utility generation use
Current Standards
• Establish a clear definition for large-scale data center
• Establish where and how they would be allowed
• Establish a clear, transparent public review process requiring Mayor and Council approval
• Must demonstrate access to adequate energy supply
• Must disclose proposed energy use and energy mix
• Must demonstrate access to adequate water supply
• Prohibit the use of potable water for cooling if not subject to the Large Water User
Ordinance
• Require additional setbacks from sensitive uses
• Require an independent noise study
• Set clear noise limitations
• Require sound walls or screening
• Require cleaner high efficiency generators and battery backup
• Prohibit load shifting (running generators instead of connecting to the grid)
• Require enhanced landscaping and right sized parking
Proposed Standards
Large-Scale Data Center
Current Standards vs. Proposed Standards

Proposed Large-Scale Data Center Definition
• Defining large-scale data centers is key to regulating them
• Size threshold of over 50,000 square feet
• General description of equipment and use
Proposed Definition for a Large-Scale Data Center
A large-scale data center is a facility, multiple facilities,
or portion of a facility on a contiguous site with the
same controlling ownership interest, and a gross floor
area greater than 50,000 square feet, housing
networked
computer
systems
and
/
or
telecommunications equipment used for remote
storage, processing, and distribution of data.
Source: Alliedbuildings.com

Proposal: Allowed Zones
Data Centers proposed to be allowed in:
• Heavy Industrial (I-2) zone via Mayor &
Council Special Exception
• Planned Area Development (PAD) OR
• Planned Community Development (PCD)
Would not be allowed anywhere by-right
Mayor & Council review approval required in all
instances

Proposed Review Process
• Public review process include a
neighborhood meeting, Zoning
Examiner public hearing, and Mayor
& Council decision
• Enhanced public notice
include notice of all property owners
within ½ mile, and all Neighborhood
Associations within 2 miles

Proposed Regulation of Energy Consumption and
Sourcing
• Demonstrate access to adequate
energy supply at time of application
• Applicant must disclose the
proposed amount of energy and
energy mix, including renewables, in
application materials

Proposed Regulation of Water Use and Sourcing
• Must comply with the City’s Large Quantity
Water User Ordinance if Tucson Water
customer
• Requires a water conservation plan
• Recycled water requirements, if possible
• Regular monitoring and compliance
• Applicant must demonstrate access to
adequate water supply
• Prohibit the use of potable water for data
center cooling, if not subject to Large Water
User Ordinance (through Zoning)

Proposed Setbacks
• Require a 400-foot setback from data center
use to urban residential areas and noise
sensitive uses such as schools
• Require a 200-foot setback from data center
use to commercial or office uses
Source: Mesanow.org
Source: City of Walnut Creek, CA

Proposed Regulation of Noise
• Require an independent
noise study that measures
sound levels & tone
• Set clear noise limits at the
property line
• Require sound walls or roof
screening around
generators and other loud
equipment

Proposed Regulation of Generator Use
•
Use cleaner, high-efficiency generators
(Tier IV or natural gas/dual fuel)
•
Battery backup used first during power
disruptions
•
No “load shifting” (no running generators
instead of using grid power)
•
Generators run only during emergencies
or required maintenance
•
Non-emergency maintenance limited to
weekdays, 9 a.m. to 5 p.m.

Proposed Landscaping and Parking Standards
• Require enhanced landscaping
borders of 20 feet.
• Define minimum parking ratios for
data center use based on
anticipated low parking needs.

Environmental Compatibility
Utilize Existing Standards, Including:
•
Require applicants adhere to existing ERZ
(Environmental Resource Zone), and WASH
(Watercourse Amenities, Safety and Habitat),
commercial rainwater harvesting, and hillside
development standards
• Includes protection of existing arroyos and
washes
• Use of low water and drought tolerant plants
• Harvest 50% of total landscape water demands
•
Utilize existing Airport Hazard District and
Industrial Use Group standards for glare.

Community Engagement, Input, and Discussion

Community Engagement, Input, and Discussion
• Community Meetings Held
• Thursday February 19, 2026, 6 - 8 p.m. In Person Pueblo High School
• Monday February 23, 2026, 5 – 7 p.m. Virtual
• Wednesday, March 4, 2026, 11:00 a.m. to 1:00 p.m. Virtual
• Thursday, March 5: 6 – 8 p.m., In-Person Rincon/University High School
• In-Person Meetings conducted in a hybrid open house style
• Break out rooms for smaller group discussion in virtual meetings
• Online and in person survey feedback, chat comments, and comments
left on posters. Over 550 unique responses have been received to date.
• All comments and FAQs document will be posted online

Primary Thems of Feedback
• Outright opposition to data centers (most
frequent theme), including calls for a ban or
moratorium instead of standards to regulate
• Water use concerns, focus on water scarcity in
a desert climate and Colorado River concerns
• Energy use concerns about increased rates and
use of fossil fuels
• Feedback that the Definition & Size
Threshold of 50,000 sq. ft. should be lowered,
consider defining by power consumption

Primary Themes of Feedback
•
Generator use concerns about fossil fuels, air pollution,
noise, and what constitutes an emergency
•
Noise concerns, including low-frequency noise,
enforcement, and potential health impacts to surrounding
residents, and that proposed setbacks are insufficient
•
Concerns that the notification radius as proposed is too
small
•
Concerns about jobs and community benefits
•
Concerns about equity
•
Concerns about accountability and enforcement

Perspective of TAC Members who Attended
Public Meetings

Discussion of Potential Changes to the Proposal

Large-Scale Data Center Definition
• Discussion of proposed size threshold of over 50,000 square feet
• Any additional feedback
Proposed Definition for a Large-Scale Data Center
A large-scale data center is a facility, multiple facilities, or portion of a facility on a contiguous
site with the same controlling ownership interest, and a gross floor area greater than 50,000
square feet, housing networked computer systems and / or telecommunications equipment
used for remote storage, processing, and distribution of data.

Enhanced Public Notice
• Currently proposed
• Notice of all property owners
within ½ mile
• Notice to all Neighborhood
Associations within 2 miles
• Discuss potential revisions

Setbacks
• Currently proposed
• 400 feet from residential zones
• 200 feet from commercial zones
• Discuss potential revision
• 1,320 feet from residential zones
• 600 feet from commercial zones

Context for a ¼ Mile Setback

Noise Standards
•
Potential identification of a community liaison on staff for each data
center
•
Potential requirement for a website by each data center to publicize
generator maintenance or other more noise intensive activities
Source: Memtech Acoustics

Backup Power / Generator Use
•
Discuss regulation of generator /
battery use in practice and identify any
specific changes, especially as they
relate to load instability and situations
where use of backup power could be
permitted.
•
How to define an emergency need?
•
Use of battery backup for community
benefit?
Source: The New York Times

Energy Generation
• Discuss potential clean energy requirement through offsets,
development agreements, etc.

Water Quality Regulation
• Discuss thermal and chemical
impacts on water quality, who
regulates this, and what
standards are already in place?

Additional Items to Consider

Large-Scale Data Center Ordinance Process
August 6,
2025
•Direction
from Mayor
and Council
Nov. 2025-
Jan. 2026
•Research
and TAC
Input
Feb. 2026 –
March 2026
•Community
Meetings
March/April
2026
•Continue to
Gather
Community
Feedback
•Mayor and
Council
Study
Session
TBD
•Planning
Commission
Review
(Study
Session)
TBD
•Planning
Commission
Public
Hearing
TBD
•Mayor and
Council
Discussion
and Public
Hearing

Attachment E - Technical Advisory Committee Membership, Meeting Summaries, and Presentations(PDF,&nbsp;13MB)

Attachment E - Technical Advisory Committee Membership, Meeting Summaries, and Presentations(PDF, 13MB)