Written submissions

Comment:: Please consider alternate locations. I understand the amount of work you went through (as I have a relative that works for Tom Dubose), but this is a terrible location for residents. The location of the project in Calipatria is great as it is no where near a large city center. I understand the certain needs for power, but it is inconceivable that it will not affect the power needs of our community in regards to summer. Rolling blackouts or even brown-outs are not out of the question. This facility is not going to improve our small town but instead is going to bring a large company (Apple, Amazon, etc.) to take over our elections with money and bring people here who will never understand our culture. The water also makes many people nervous. But! do not understand enough about what they will use vs. take in with the new wastewater treatment plant. This entire project needs to be more transparent. You need to have a press release come out highlighting safeguards that you have in place to protect the actual residents who live there, besides the fact that you can't actually protect those that live in close proximity from the electrical currents that come from the facility. For those of you that laugh at that comment, just remember cigarettes used to be deemed "safe". You need a better marketing company to help ease the citizens worries and be honest about it all.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: Location should be at least 10 miles away from any residence, is common sense. We need more fire houses before you allow this projects near houses. Have some common sense, and we need good politics in this county.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: No data centers near our homes. Allinformations shows. Data centers affect residents economically and health wise. I oppose 100% to that data center

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: To Whom It May Concern, We are submitting this comment first and foremost as parents and residents of the Victoria Ranch subdivision. My wife and I recently purchased our home after years of hard work, with the goal of providing our children a safe and healthy place to grow up. We chose this neighborhood because it offered a residential environment where our children could play outside, walk to school, and experience the sense of security every family hopes to provide. Learning that a large scale data center and Battery Energy Storage System facility is proposed within a ten minute walk of our home has been deeply distressing. Our concerns are personal and immediate. This project would place large backup generators, electrical substation infrastructure, and continuous industrial operations directly adjacent to our neighborhood. These impacts would exist where our children sleep, play, and walk every day, not in a distant industrial zone. We are especially concerned about emissions, noise, and the long term presence of heavy energy infrastructure so close to residential homes. Compounding this concern is the fact that an existing elementary school is located less than a mile from the proposed site, and a new school is actively being built in the same area. The placement of industrial scale infrastructure near homes and schools raises serious health, safety, and land use compatibility concerns. We have participated in the County process in good faith. During the Imperial County Planning Commission meeting on December 18, 2025, where the initial lot merger item related to this project was considered, more than three and a half hours of public comment were provided. The overwhelming majority of speakers voiced opposition or serious concerns. Additional opposition was expressed during a data center workshop hosted by IID and again during the January 13, 2026 Imperial County data center workshop. Despite this sustained public participation, the project appears to be advancing without meaningful consideration of community concerns. We are particularly troubled by the apparent reliance on administrative or ministerial pathways that avoid full review under the California Environmental Quality Act. CEQA was established specifically to require comprehensive environmental analysis for large scale developments that may significantly affect public health, safety, and quality of life. As residents, this review is a protected right. We are deeply concerned that by treating this project as routine development, discretionary review is being bypassed and the environmental, health, and quality of life impacts to surrounding families are not being fully studied or disclosed. We are not opposed to innovation or economic development. However, projects of this magnitude must be evaluated transparently and responsibly, with full environmental review and meaningful community engagement. The proximity to residential neighborhoods and schools alone warrants the highest level of scrutiny. We respectfully request that Imperial County require full CEQA review, thoroughly evaluate health and environmental impacts, and meaningfully consider community input before any approvals move forward. Thank you for the opportunity to submit this comment.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | CORRECTED 2026-09-23 (Lane 2 OCR proof vs County PDF): "notin" -> "not in" and "anda" -> "and a" (OCR dropped spaces; PDF p.2 reads "not in", "and a").

Comment:: Hola Yo soy un residente del Valle Imperial, As a technical expert in a number of disciplines, I know that this project is doomed for failure before breaking ground. Hi my name is I am a Cal Poly San Luis Obispo Alumni with a degree in Food Science and former IBEW 569 apprentice. I have worked in agriculture: farming, precision leveling and drainage tile installation for a majority of my life. The data from sources like Imperial Irrigation districts regarding power consumption over a year. Data collected from the wind farms about wind speed and intensity. Data from local geothermal plants about sediment issues and other environmental factors. Also compiling NOAA data to determine how low pressure systems affect heat intensity. These are all analysis that should be done prior to any construction. My lived experience in the Imperial Valley assures me this hasn’t been properly evaluated.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: Hello, I am leaving a comment in regards to the proposed data center. I am wholly against it as I believe it would push the Imperial Valley's resources to a limit we can no longer afford. Our Valley is growing and new businesses and enterprises are welcome, but not at the expense of its people and its resources. This data center and its builders seems to have wanted to establish itself without regard for the resident's of Imperial input or without any environmental review. I was shocked to hear that such a thing was even being considered. No letter, no news, no announcement. The company behind this data center has done so much to keep this project under wraps from the people who it will affect the most. This company does not care for the valley. They say it will bring jobs and money, but the data center will only take water, energy, and jobs away from people who need it the most. They say its Google who will be using the data center. To that! ask, will Google invest in this community? Will Google invest in our schools, in our hospitals, in our people? Will they only take our water and leave us with pollution?Please do the right thing and deny this data center from being built. The valley is growing and new business, both local and national, are establishing themselves here. We don't need this data center to prove that we are welcoming to innovation. Data centers are not innovation. AI is not innovation. Taking away jobs from people and calling it efficiency is not the way to grow and flourish our valley. Please, consider what this data center will take away from this valley and from its people. Please do the right thing and say no to this proposal. So no to the data center. Thank you.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | CORRECTED 2026-09-23 (Lane 2 OCR proof vs County PDF): "Al is not innovation" -> "AI is not innovation" (OCR read capital I as lowercase l).

Comment:: To All County Board of Supervisors: Re: Proposed data Center (Imperial & Aten Road) Most residents in Imperial County are opposed to the proposed location of the Data Center in the City of Imperial, Ca. The way the Board of Super- visors went about entering into an agreement with the developers of the project without a CEQA or EIR is quite concerning to all county residents. A project of this magnitude will have a long-lasting impact on the quality of life and the limited resources of Imperial County. CTR has announced the launch of Data Power energy complex to deliver 600 mw specifically for the purpose of supplying energy to Data Centers. The ideal location for data centers would be in the area where the Geothermal plants are located to have direct supply to energy produced from these plants. The data center can develop methods to cool the steam extracted in the drilling process as a source to cool the servers. The developers interested in establishing data centers in Imperial County have the resources to develop the technology necessary to implement such a plan. Tax revenue would still be generated for the County, which is the sole focus of the Board of Supervisors. Regardless of the amount of revenue generated from the proposed data center project, it should never be considered without a CEQA and EIR study to mitigate the effects on the quality of our lives and of our children.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment: Good morning Board of Supervisors, I have several questions regarding the proposed AI dat center located at Aten and Cross Road. 1. Why is “data center” in M1 permitted use? What studies were conducted to determine this category? When was the last study completed for that specific use? 2. Will the developer flip this project to one of the 5 hyper scalers? If so how will you keep promises made by the developer? 3. Will you give the hyper scalers tax’s breaks in the future? 4. Where does the discharged water go? What biocides, corrosion inhibitors, and heavy metals and/or other elements will be added to cool these systems? 5. People are afraid of health risks. Will you require CEQA and EIR? 6. If there is an AI bubble and hyper scaler stop mid construction will you still be able to collect taxes? 7. When will the sales tax be collected if this project moves forward? After they are up and running or when the developer flips it to the hyper scaler or another time? 8. How is the noise going to be addressed? Thank you for your time

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | CORRECTED 2026-09-23 (Lane 2 OCR proof vs County PDF): "Al dat center" -> "AI dat center" and "Al bubble" -> "AI bubble" (OCR l/I); "7.When" -> "7. When". "dat" is [sic] per PDF.

Comment:: This data center is proposed to be located in the midst of three residential neighborhoods. To determine that a project of this kind is a "ministerial" exemption to CEQA because of zoning done decades ago, is, at least, an outrageous violation of the spirit of CEQA. At most, it is a violation of state law. There is currently clear documentation that at least one county department sent to the proponent, a letter which stated that this project is discretionary and therefore subject to CEQA analysis. After this, a determination was made by others that the project is exempt. Even now, the Air Pollution Dept has requested further analysis and yet, despite this, the project has been placed in front of the planning commission for recommendation of approval. This project carries the potential of significant impacts to nearby residents and to consider approving it without an Environmental Impact Report, with its attendant impact analysis and commitment to mitigation of impacts constitutes a breach of trust with nearby residents and the people of Imperlal County as a whole. The HRA does not examine the full impact of the generators as it does not assess the potential impact of the entire number of generators turned on at once or for a significant period of time. Worse, it includes no cumulative impact analysis to determine if this project will add to the baseline pollutants in the air and create an unhealthful condition.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: What do you intend to do about ensuring that chemical agents and general pollution that come from cooling that the data center needs doesn't contaminate the local water? Furthermore, how do you intend on preventing the data center from destroying our already fragile electric grid? How do you intend on preventing the contamination, that comes from every data center that has been built, from raising cancer rates in this city with extremely limited cancer treatment resources? These solutions must be new and effective, because other data centers that have failed became a catastrophy that is still plaguing those communities.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors. "catastrophy" is [sic].

Comment:: NO! This should not be in the valley where so many vulnerable people live.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: I SAY NO DATA CENTER IN MY BACKYARD

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: NO DATA CENTER IN MY BACK YARD.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: Please build this damn thing. Our community needs development and we need new sources of revenue that do not include an increase in taxes. I find it amusing so many folks who live close to the proposed site are opposed to the project meanwhile, Kinder Morgan has been operating for decades across the street. Not one but two gas pipelines go through that area and nobody blinks an eye. Let them protest, they will get over it and go about their lives. As a resident of Imperial! want to see this project built and see my city flourish. "Anywhere but California" Sad but true.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: I believe the data center should proceed if safeguards are built in to ensure the data center developer covers all costs asso- ciated with electric and water utility infrastructure upgrade costs so no additional fees or increase in rates are passed along to existing residents or businesses. The tax revenue and jobs will be good for the Imperial County.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. Support is conditional on the developer paying utility-upgrade costs. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors. "asso-/ciated" line-break hyphen is as printed.

Comment:: The imperial county has many places to put a data centers not closeto a residential area , the Blair rd north east of calipatria will be a good place ,it has potable water a gss line to run generators, also sewer line, thers 2 industrial lot already there the farm ground marginal that will only grow bermuda, also any data center that wants to come to the imperial valley should be require to build 70 acres of dolar farm to help the iid grid.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors. "closeto", "dolar", "gss", "thers", "iid" are [sic] per PDF p.4.

Comment:: I want to be on record opposing the Imperial Data Center project. The following excerpt is from a KPBS piece on the project: "For more than a year, a mammoth $10 billion data center project has been quietly moving forward in the heart of California’s Imperial Valley. The facility could consume almost double the amount of electricity that the entirety of Imperial County used in 2024 But Rucci also had another goal in mind: to plan the project in a way that would allow it to avoid facing an environmental analysis under the California Environmental Quality Act (CEQA), the state’s landmark environmental protection law. Rucci’s turbulent business history. Across the country in Ohio, his previous business ventures have left a trail of criminal investigations and legal complaints. In 2010, local county prosecutors charged Rucci and several other people with money laundering, promoting prostitution and perjury at a night club which he owned in the Ohio city of Youngstown, state court records show. The felony charges against Rucci and the others were eventually thrown out, some because the case took too long to go to trial. Rucci was convicted of selling beer at the club with an expired license in 2014. He served 30 days in jail. Rucci pivoted, starting a hotel-turned-treatment center for drug addiction called California Palms at the same location. (He originally had plans for an inn named Hotel California but was sued for trademark infringement.) Ohio health officials inspected the treatment center and found staff had provided false information about the facility’s clients and staff, falsified signatures, broken various health care protocols and failed to provide an appropriate amount of treatment in some cases, according to a 2021 state report. State officials revoked the treatment center’s certification, which led to termination of the center’s Medicaid contract." Imperial County officials should be very leery of Mr. Rucci, and make a greater effort to protect the county and its residents from unscrupulous and greedy parties.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: Our community is more important! This money hungry center isn't going to solve our problems but make it worse. They aren't going to provide safe long term jobs, this is an industry that isn't going to last long! It has been around for a few years and it's impact has already damaged so much of our environment. It's going to be a big pile of abandoned buildings rather than something more positive Note: This comment was received 7 times through different individual submissions.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. County note on the PDF says this identical comment was received 7 times through separate submissions; cataloged once here, count 7. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: We do not want it. It’s ridiculous to have ANY type of thing that requires large amounts of energy and water in a hot desert— -not to mention near residential areas and not far from a school.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: Build it

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: The facility will introduce a large, continuous base load that coincides with regional peak demand periods, increasing stress on an already constrained grid. What peak load modeling has been performed and how will this project avoid increasing regional peak demand or emergency curtailment events?

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: I’m a resident of Imperial and a parent with serious concerns about the proposed Imperial Data Center project. I’m asking why this project cannot be located on unincorporated County land AWAY from residential neighborhoods? I have one child with a sensory disorder and increased noise would significantly affect her well being. I also have another child with asthma and I’m concerned about how this project may impact air quality. A full CEQA environmental review is the only process that would provide clear transparent answers about how this project will affect my children’s health. Without it families like mine are being told to accept unknown risks. The County needs to reconsider the location AND require a full CEQA review before moving forward.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: We don’t want this here. Our valley already struggles with water and electricity requirements for the people who live here, and we help as much as we can by adhering to strict hours of operation, without the added burden of a data center. The jobs promise, the water promise and the no noise promise are just that, promises, and in the valley promises are always broken. We cannot allow this to go thru because at the end of the day the developers and owners will not be living here, will not have to deal with the fallout, and the only ones suffering will be us. Please do not allow this to go thru. Search videos of people already living near data centers who were given these same promises and you will see what is headed our way if we allow this to happen.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: I am for Data Centers in Imperial Valley. I understand the one everyone is talking about is not in Calipatria but I am for ANY project moving forward in this Valley. In my view and through my research I know that every state has different ru& requirements needed to construct or permit a project (data center), where to build, what needs to happen, how close in reference to homes, cites, schools etc. Anyway I am in favor of projects here in Imperial County as long as they are built up to local regulations.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: My name is [redacted] I was born and raised in Brawley. But my dad lives just a stone’s throw from the land where you’re considering placing this massive data center. This is my home. My family’s home. And like so many of you, I live here because I believe in this community — a place where neighbors look out for each other, where our kids can play in the yard without fear, and where families raise the next generation with pride and hope. I moved my family back here from Oregon last year for that exact reason. I wanted my 2-year-old son to grow up here — safe, cared for, and surrounded by family and community. I personally can’t afford childcare, so my son stays with his grandma and grandpa while his dad and I work. That’s the life I chose here, and now that sense of safety and wellbeing is in jeopardy. So I spent 15 years in Oregon — a place with abundant fresh water by the way — and I saw firsthand how communities have been grappling with real problems tied to large data centers. In towns like Boardman and Morrow County, data facilities can use more than a million gallons of water ina month just for cooling alone. Residents in those areas have watched water supplies get strained, and some are now facing contamination crises with well water nitrates far above safety standards. There are issues from the centers there being linked to cancers and miscarriages, and leading to lawsuits over drinking water contamination. I’ve seen it with my own eyes. So let’s be clear: even where water is plentiful, the impact is real. So here in the Valley — where water is already scarce and precious — we cannot treat this like an acceptable trade-off. You can talk about using reclaimed water all you want, but the fact is: this project hasn’t undergone a proper environmental review. That’s not just an oversight or bad project management — that’s putting the burden on us, the residents, after the fact. You keep telling us this project will bring jobs. Jobs, jobs, jobs — like saying the word enough times will make it true. But let’s be honest: most construction jobs for a project this specialized don’t go to everyday local workers. They go to crews with specific tech-infrastructure skills brought in from outside. And once construction is over? Permanent jobs are few and far between. That’s just straight up deception, and not the kind of economic lifeline our families really need. You tell us there won’t be environmental impacts, yet required environmental reviews were skipped or fast-tracked. You tell us not to worry about strain on our water and power systems, yet we are already told to conserve water here every season and face power outages when summer heat spikes. And lastly, with everything happening in our country — from blatant dismissals of truth in Minnesota all the way to corporations hiding environmental impacts elsewhere — we see the same pattern here on a smaller scale in our community. When you prioritize speed and profit over transparency and community wellbeing, that’s a betrayal of public trust. I know I certainly won’t forget the the names and titles of those on this board and others involved who dismissed it. You already told folks they can’t peacefully protest. What sort of tactics will you deploy next to get what you want? So, will you actually stand with the families who live here, whose kids go to school down the road? Will you protect our water, our air, and our future? Or will you be remembered as the ones who chose short-term promises over the long-term health and safety of the people who actually live here?

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. Name replaced with "99899" in the County posting. Continues across pp.6-7. | CORRECTED 2026-09-23 (Lane 2 OCR proof vs County PDF): "My name is 99899 I" -> "My name is [redacted] I" (99899 was OCR of the County redaction box, PDF p.6); "onasmaller" -> "on a smaller"; removed stray page-break character.

Imperial County Board of Supervisors 940 W. Main Street El Centro, CA 92243 Re: Opposition to Lot Merger No. 00191 and Proposed Data Center Project (Clark & Aten Roads) Dear Chair and Members of the Board: On behalf of the Sierra Club San Diego and Imperial County Chapter and its over 9,000 members, we respectfully submit this letter in opposition to Lot Merger No. 00191 and the proposed data center project near Clark Road and Aten Road. As detailed in the City of Imperial’s formal objection and protective appeal, the proposed lot merger raises serious legal and procedural concerns. County Ordinances require that lot mergers first be properly considered and decided by the Planning Commission before any appeal to the Board. In this case, the Planning Commission did not approve the merger; instead, it directed further consultation with the Cities of Imperial and El Centro and the community before reconsideration. Moving forward without a final Planning Commission determination risks violating County ordinances and rendering any approval null and void. The City’s appeal letter further outlines substantive legal deficiencies, including concerns that: • The parcels are not under common ownership and may not qualify for merger under Government Code § 66499.20.3. • The parcels are separated by a public road, raising questions about contiguity and compliance with County Ordinance 90808.00. • The proposed merger conflicts with single-base zoning requirements and the Urban Overlay (“U”) zoning designation, which requires coordination with the City of Imperial. • Required Airport Land Use Commission review has not occurred. • The merger and associated CEQA determinations may be inconsistent with state and local law. Additionally, the City of Imperial’s November 17, 2025, comment letter highlights the lack of full project transparency. The City has not received complete project details, including building specifications, infrastructure demands, and full environmental documentation. Given the project's proximity to existing homes, the City appropriately requested a comprehensive environmental review, traffic analysis, coordination with City services, and an Airport Land Use Commission review. These requests remain unresolved. Beyond the lot merger, significant environmental concerns remain. The applicant has reportedly applied for permits for 100 gas-powered backup generators, and the Air Pollution Control District has required additional air quality analysis. The scale of this proposal, along with anticipated traffic, energy use, battery storage, substations, and potential water demand, warrants full and transparent environmental review, not piecemeal approvals. We are also concerned that a building permit has not yet been approved, and the prior CEQA exemption applied only to grading. Approving the lot merger at this stage would advance a major industrial project without a complete review of its cumulative impacts. For these reasons, Sierra Club members urge the Board to: 1. Deny Lot Merger No. 00191; 2. Require full compliance with County ordinances, the Subdivision Map Act, CEQA, and Airport Land Use Commission requirements; 3. Ensure meaningful consultation with the City of Imperial, the City of El Centro, and affected residents; and 4. Require a comprehensive environmental review of the entire data center project before any further discretionary approvals. The scale and potential impacts of this project demand transparency, legal compliance, and robust environmental review. We respectfully request that the Board uphold these standards and deny the proposed lot merger.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. Posted as a letter with no "Comment::" header, separated from unit 25 by a divider (checked visually on p.7). | CORRECTED 2026-09-23 (Lane 2 OCR proof vs County PDF): restored the 5 bullets of the City appeal-letter list (OCR had "e " for 3 bullets and dropped 2 bullet markers, merging "Required Airport..." and "The merger..." into prose; PDF p.8 shows 5 bullets); removed stray page-break character. Numbers checked against PDF: Lot Merger 00191, Gov Code 66499.20.3, Ordinance 90808.00, 940 W. Main, 92243, 9,000 members, Nov 17 2025.

Comment:: Not a resident of El Centro or Imperial County but I am resident of California. That this facility will be using anywhere from 800,000 to close to 6 million gallons of water a day is obscene! We are a state that is in dire need of all the water we can get. To give our water to a company that is not only trying to bypass CEQA practices should tell you all you need to know on how they're going to screw over the community & this state. They will search for and use every tax break in the book that they can to end up paying little to no taxes in the county & state. They will most likely be paying less taxes than the hard working people of the community.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: I need the "preliminary change of ownership report".

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: Please let me have the form by email.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: Is the developer, Mr. Rucci, have any agreements to get water from Imperial Valley College's waste water plant?

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: Has the County of Imperial confirmed whether the property owner for the proposed Imperial Valley data center has received a written approval of a Soil Management Plan from the California Department of Toxic Substances Control, as required under the land use covenant recorded on the property deed? If such approval has been granted, why has the County not made this document publicly available, given that it is a prerequisite tied to environmental protections for the site? Additionally, how does the County reconcile its determination that the project is ministerial when the State of California, through DTSC, must exercise regulatory discretion to review and approve the Soil Management Plan to protect surrounding neighborhoods from potential contamination risks? If such approval has not been granted, how does the County intend to proceed with project approvals while a recorded land use covenant requires this DISC approval prior to disturbance of soil? In that case, what is the County’s legal basis for treating the project as ministerial if compliance with the covenant appears to require discretionary state review?

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | PROOFED 2026-09-23 (Lane 2): text checked against County PDF by independent 400-dpi re-OCR diff plus visual check of flagged spots; no text errors.

Comment:: The proposed data center may serve outside interests, but it comes at a real cost to the people who call the Imperial Valley home. We already live with the reality of limited water. Every resident understands how precious water is here. Approving a water-intensive data center in a region that struggles with water scarcity sends the message that corporate demand matters more than the long-term needs of our community. This project is also proposed right next to homes and a band new school that is currently being built. Families deserve quiet, safe neighbor- hoods, not constant industrial noise, backup generators, and air quality concerns next to where children learn and play. Our kids should not be the ones paying the price for a decision they had no voice in. What makes this even harder to accept is that once built, this facility offers very few permanent jobs, yet leaves a permanent impact on our land, resources, and quality of life. I urge you to listen to the residents who live here, raise families here, and depend on these resources every day. Please reconsider this proposal and choose development that truly respects and protects our community.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. | CORRECTED 2026-09-23 (Lane 2 OCR proof vs County PDF): "projectis" -> "project is" (PDF p.9). "band new" is [sic].

Comment:: Comment in support of the Data Center attached. [Attachment] As a long-standing property owner and taxpayer in the City of Imperial for nearly two decades, I want to express my support for the proposed Data Center project located at the corner of Aten and Clark Road, Imperial Valley Computer Manufacturing, LLC. My business is a neighboring property to the planned development, giving me a unique perspective on its importance to the local community. This Data Center has been in the planning stages for many years and represents a significant opportunity for economic growth in the Imperial Valley. The project is expected to bring new jobs, increased business activity, and a positive influence on the local economy. It will give our isolated Valley stronger internet for all, especially in the case of emergencies, such as earthquake, fire or flooding. I also recognize the economic benefits that the development will bring to the Imperial County. The business property tax bills alone will contribute an extraordinary amount to the county. Imperial Valley Computer Manufacturing, LLC seems to be committed to supporting initiatives that enhance the prosperity and quality of life in Imperial County. I believe that the Data Center project aligns with the county’s long-term vision and will contribute to making Imperial Valley a center for innovation and technology. In conclusion, I urge city and county leaders and stakeholders, after due diligence, to support the Data Center project. It could be a milestone in the economic development of Imperial Valley, reflecting the collective aspirations of businesses and residents, like myself, who have invested in this community for years.

Proof status: source_verified_ocr_proofed. Text is OCR (tesseract, 300 dpi) of the County-posted PDF; OCR "|" restored to "I"; proof against the PDF before publishing. County removed identifying info, so no spoken-row cross-link is possible. The form comment points to an attached support letter (p.10), included here. | CORRECTED 2026-09-23 (Lane 2 OCR proof vs County PDF): removed stray page-break character before [Attachment].