The URL can be used to link to this page

Home My WebLink About2026-09-22 OSCER Comments From: Acasio, Laura To: Planning Internet Mail Cc: Kimball, Heather; Botelho-Kaili, Dorthi; Darrow, Jeffrey W.; Ley, Rachelle; Camero, Tracie-Lee; Steen, Raimee; Dacayanan, Melissa Subject: RE: RE: Request for Comments | County Council Initiated (PL-CCI-2026-000018) Bill No. 170 Relating to Zoning for Data Centers Date: Tuesday, September 22, 2026 11:10:09 AM Attachments: OSCER Windward Planning Communication Bill 170.pdf image001.png Submitting communication for Windward Planning Commission October 1, 2026. Please see attached. Mahalo, Laura From: Acasio, Laura Sent: Monday, September 21, 2026 9:42 PM To: Planning Internet Mail <planning@hawaiicounty.gov> Cc: Kimball, Heather <Heather.Kimball@hawaiicounty.gov>; Botelho-Kaili, Dorthi <Dorthi.Botelho- Kaili@hawaiicounty.gov>; Darrow, Jeffrey W. <Jeff.Darrow@hawaiicounty.gov>; Ley, Rachelle <Rachelle.Ley@hawaiicounty.gov>; Camero, Tracie-Lee <Tracie-Lee.Camero@hawaiicounty.gov>; Steen, Raimee <Raimee.Steen@hawaiicounty.gov>; Dacayanan, Melissa <Melissa.Dacayanan@hawaiicounty.gov> Subject: RE: Request for Comments | County Council Initiated (PL-CCI-2026-000018) Bill No. 170 Relating to Zoning for Data Centers Please see attached communication RE: Bill 170 and feel free to reach out if you have any questions or need further detail or clarification. I will re-submit for the Windward Planning Commission as well. Thank you, Laura C. Kimo Alameda, Ph.D. Mayor Laura Acasio Director Hawai`i County is an Equal Opportunity Provider and Employer County of Hawai’i OFFICE OF SUSTAINABILITY, CLIMATE, EQUITY, AND RESILIENCE 32 Kino'ole Street, Suite 101  Hilo, Hawai’i (808) 854-3129 E-mail: OSCER@hawaiicounty.gov WINDWARD PLANNING COMMISSION Thursday, October 1, 2026 9:30 AM Hawai‘i County Council Chambers in Hilo 25 Aupuni Street, Hilo, Hawaiʻi 96720 COMMENTS ON AGENDA ITEM 1: INITIATOR: COUNTY COUNCIL (PL-CCI- 2026-000018) Bill 170, an ordinance amending Chapter 25 (Zoning), Article 1, of the Hawaiʻi County Code (2016 Edition, as amended), relating to zoning for data processing facilities and data centers. The purpose of Bill No. 170 is to amend the definition of data processing facilities and add a new definition of data centers. Aloha e Chair Daniele III and Honorable Commission Members, The Office of Sustainability, Climate, Equity and Resilience (OSCER) appreciates the opportunity to provide comments on Bill 170 and supports the intent of the measure to establish a clear distinction between data processing facilities and data centers and the clarification that data centers are not a permitted use in the County. OSCER recommends, however, that the distinction be sufficiently clear and unambiguous to identify facilities whose scale, energy consumption, cooling requirements, water demand, and associated infrastructure create significant impacts that warrant additional consideration under the County's land-use, infrastructure, environmental, and public-health policies. Hawaiʻi County has recently adopted General Plan 2045, effective June 26, 2026, establishing a policy framework for sustainable and resilient development. Additionally, the County's Integrated Climate Action Plan (ICAP) provides adopted policy direction concerning energy, water, climate resilience, and development. In addition, Chapter 37, Hawaiʻi County Code, establishes sustainability, climate, equity, and resilience as County policy and provides OSCER with a mandate to advance these objectives, including consideration of equity and environmental justice in County decision-making. Together, the General Plan 2045, ICAP, and Chapter 37 provide the adopted policy framework that informs the following comments on Bill 170. C. Kimo Alameda, Ph.D. Mayor Laura Acasio Director Hawai`i County is an Equal Opportunity Provider and Employer Water and Natural Resources General Plan Objective 26 calls for increased protection of existing and potential sources of drinking water. Policy 26.10 specifically provides that water-demand projections shall include “all consumptive and non-consumptive demands,” while Policy 26.15 calls for new development to reduce water demand, retain runoff, decrease flooding, and recharge groundwater. These policies are particularly relevant to the distinction between data processing facilities and data centers because the water requirements of a data center may extend beyond occupancy-related water demand to include process-related demands associated with cooling and other facility operation needs. Energy and Climate General Plan Objective 29 is to “Strive towards energy self-sufficiency.” Policy 29.1 calls for energy production and distribution to be adequate, efficient, and dependably available to support present and future demands. Additionally, the ICAP provides particularly relevant guidance. In discussing increasing temperatures and energy demand, the ICAP specifically identifies data servers and states that “technology like data servers require immense amounts of cooling,” increasing energy demand as temperatures and technology use rise. The ICAP further recognizes the connection between increased energy demand and greenhouse-gas emissions. This direct recognition of data server cooling requirements supports consideration of energy intensity and cooling demand when distinguishing a data center from other data- processing or technology uses. Infrastructure, Environmental, and Community Protection General Plan Policy 13.29 provides that industrial development should be located in areas adequately served by transportation, utilities, and other essential infrastructure. General Plan Policies 25.1–25.3 further call for utility facilities to be appropriately scaled, effectively serve community needs, and minimize pollution or disturbance of the natural environment and natural resources. These policies support a clear distinction between ordinary technology uses and facilities whose scale and operational characteristics can create substantial demands on electrical, water, transportation, emergency, and other public infrastructure. OSCER also notes that the General Plan's resource policies and the ICAP's climate resilience objectives require consideration of potential impacts to water resources, energy systems, greenhouse-gas emissions, stormwater, natural resources, environmental quality, and public health and safety. C. Kimo Alameda, Ph.D. Mayor Laura Acasio Director Hawai`i County is an Equal Opportunity Provider and Employer Equity and Environmental Justice Equity and environmental justice are cross-cutting considerations under the County's adopted policy framework. Chapter 37, Hawaiʻi County Code, directs the County to consider cumulative impacts on “lower and middle income, Native Hawaiian, and historically marginalized communities” and to implement sustainability, climate, and resilience policies equitably, while ensuring that these efforts benefit communities who experience greater environmental and climate-related burdens. Consistent with these requirements, consideration of data centers should extend beyond their individual site impacts to include the distribution of benefits and burdens associated with increased demands for water, energy, infrastructure, land, and other public resources, including implications for the availability, affordability, reliability, and resilience of those resources for existing communities. Concluding Comments Consistent with the policies discussed above (but not limited to) and the intent of Bill 170, OSCER supports establishing a clear and meaningful distinction between data processing facilities and data centers. OSCER recommends that the definition identify objective characteristics relevant to a facility's scale and material resource and infrastructure demands, rather than relying solely on the type of digital activity performed. Such characteristics include electrical demand measured in megawatts, water consumption or withdrawal, cooling capacity, and the scale of associated utility and support infrastructure. Additionally, OSCER recommends that the definition address the potential aggregation of facilities, including facilities located on the same campus, on contiguous or adjoining properties, or developed in phases, where their combined operations or resource demands are functionally interconnected. This will ensure that facilities are considered based on their cumulative scale and resource demands when they essentially function as a single data-center operation. OSCER recommends that the definition be developed consistent with the County's adopted policy direction concerning water availability and resource protection; energy consumption and infrastructure capacity; cooling and associated resource demands; greenhouse-gas emissions and climate resilience; environmental quality and natural- resource protection; and public health, safety, equity, and community compatibility. A clear and meaningful definition will provide an important foundation for the County to identify and appropriately regulate data centers consistent with the adopted policies of General Plan 2045, the Integrated Climate Action Plan, Chapter 37 and other relevant County policy. C. Kimo Alameda, Ph.D. Mayor Laura Acasio Director Hawai`i County is an Equal Opportunity Provider and Employer The Office of Sustainability, Climate, Equity and Resilience appreciates the Commission's service to the County and the time and attention you have given to this matter. OSCER remains available to answer questions, provide further advisement, and support continued collaboration as needed. Thank you for your service to the Hawaiʻi County community and for the opportunity to provide these comments. Respectfully, Laura Acasio, Administrator