Sugarloaf Alliance

What's the Impact of Anticipated Data Center Development

on Our Water Supply?

Comments delivered to the Frederick County Planniung Commission, 11/12/24

 

Sugarloaf Alliance appreciates the staff work that has gone into this forward-looking water resources report. However, with development of a new large industry (data centers) in Frederick County, we recommend that the FCPC report address this new industry explicitly and as comprehensively as possible. (1)

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Although water consumption information is often difficult to ascertain, estimated water use for a mid-size data center is around 300,000 gallons per day (2), and researchers estimate water use for large data centers “can be as much as 5,000,000 gallons per day” (3).

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Our concern becomes evident when one compares these numbers to the currently permitted withdrawal at the County’s main water treatment plant (the New Design treatment plant). The permitted withdrawal is 16,000,000 gallons per day, and even without a full estimation of Frederick County data center water needs, water use is expected to significantly increase. Conceivably, this expected increase could change by orders of magnitude, depending on the full build-out of data centers on as much as 10,000 acres of land. The original Amazon Plan estimated a total consumption of 2,040,000 gallons per day (see attachment). Have data center volumes like these been included in the estimated demand increase of 3.3 MGD by 2035?

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At the very least, this report should provide some analysis and insight into the impacts of anticipated data center development on our water supply, treatment capacity, and surface and ground water quantity and quality.

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The Basis of Estimation of Future Needs is Unclear and Flawed

 

The introduction of this Report states that:

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Estimates for future conditions are informed by three sources: the residential pipeline, Round 10.0 cooperative forecasts from the Washington Metropolitan Council of Governments, and County and municipal staff knowledge of local plans, trends, and constraints. The WRE considers two time periods (2035 and 2050).

 

A general 5% increase in residential development and job growth does not accurately or sufficiently predict growth in demand for water resources when a new major industry (data centers) is being developed. Also, the section on projecting population growth and development (pages 1-10 through 1-12) does not address the expected growth in the data center industry in the county.

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This a major failure of the report and could greatly impact the effectiveness of planning for the future. Again, please realistically address the expected increase in data center development in this report.

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Investing in Workers and Workplaces

The county has undertaken a separate inquiry, dubbed “Investing in Workers and Workplaces,” which demonstrates the County government’s desire for an increase in the amount of commercial and industrially zoned land in the county. How has this study been reflected in the future-looking water resources report?

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More Detail Needed to Understand What Is Covered Under “Quantum Data Center Campus”

The plan states that “the Quantum Frederick Data Center campus is located within Ballenger- McKinney WWTP service area. The projected wastewater yield for this project has been included in the Projected Flow for 2035 and 2050.” However, it’s not clear how much of this “project” is represented in the estimates. Is it only the data centers that have currently applied for permits, or is it the complete Quantum Loophole area? Please clearly state in detail the data center facilities that are included in the estimates representing the Quantum Data Center Campus in this report.

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Disclose Level/Factors of Uncertainty in Estimation for Future Water and Sewer Use

With the level of specificity of estimation results, one would expect that accuracy is high; however, again, the expected growth of the data center industry is not clearly represented in this report. If the County has more accurate estimates of the amount of water expected to be used, sharing that information would be helpful to present a full picture of expected water- related needs in the future. Clarity concerning the level of uncertainty in the estimated future numbers - either in numeric or conceptual form - is necessary to maintain credibility of this document.

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Additional Specific Recommendations

-Add a section to the report that directly and comprehensively addresses the expected growth of the data center industry in Frederick County and its potential impact on all facets of water resources.
 

-At a minimum, include a bounding analysis that shows both high and low numbers for water supply and for wastewater treatment demand that represent the estimated upper and lower bounds of possible data center site development.
 

-Add language clarifying the level of confidence of the estimates, including level of uncertainty due to data center growth.

 

-Page 2-21 and 2-22 address low flow augmentation which can be triggered if any permit allows for “consumptive water use if the maximum consumptive water use can exceed 1-million gallons per day (1 MGD) at any time.” We appreciate the statement that “Future planning efforts that focus on the establishment or development of industrially zoned land that can support packaging plants or technological applications like data centers should be undertaken with consideration othe implications of consumptive use,” and the clarity of “the establishment of an augmentation system represents a significant investment in terms of time, effort, and expense which should borne by permittees and not the citizens of Frederick County.”

Again, we believe that, to best support planning efforts in the county, the possibility of large data center consumptive use should be more fully explored and future use projected with the rigor the report uses to consider residential growth. Are there any anticipated data centers or groupings of data centers that could trigger this threshold?

 

The report does not address the high potential for extensive data center development throughout the southern part of the county. If the Quantum facility is fully built out, how much water would be expected to be used consumptively and would it be above 1,000,000 gallons per day at any time?

 

-Also, for purposes of accuracy, could the County confirm whether Quantum Loophole still plans to use grey water from the Ballenger-McKinney Wastewater Treatment Plant, the status of the construction of the expected pipeline, and the expected timeframe? Will Quantum Loophole have to construct any sort of grey water treatment system prior to being able to use this water? Also, are there concerns about the amount of salts potentially expected to be in any wastewater discharged from data centers to county- owned waste water treatment plants?

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(1) https://www.npr.org/2022/08/30/1119938708/data-centers-backbone-of-the-digital-economy-face-water-scarcity- and-climate-ris
(2) https://www.npr.org/2022/08/30/1119938708/data-centers-backbone-of-the-digital-economy-face-water-scarcity- and-climate-ris

(3) https://www.washingtonpost.com/climate-environment/2023/04/25/data-centers-drought-water-use/