Alan Davidson
Assistant Secretary of Commerce for Communications and Information
National Telecommunications and Information Administration
1401 Constitution Avenue NW
Washington, DC 20230

Re: Request for comment NTIA–2024–0002

We appreciate the National Telecommunications and Information Administration (NTIA) and the U.S. Department of Energy (DoE) undertaking this Request for Comment on the impacts of data center growth across the United States.

Today, a handful of the wealthiest technology corporations are building out energy-hungry data centers at a rate that is outpacing our ability to build renewable energy. This growth threatens to reverse hard-won climate progress made by the Biden-Harris Administration, at a time when we can no longer afford delays. Much of this growth is driven by this handful of corporations racing to dominate artificial intelligence and cloud computing markets in an effort to cement their power into the future. At the same time, key players in our energy system – dominated by investor-owned monopolies and private equity-owned fossil fuel producers – have been willing accomplices, failing to protect ratepayers or prioritize the need for renewable energy infrastructure.

The administration has a critical role to play in ensuring we invest in an energy and technology future that serves the public interest. To set a new trajectory, we urge the administration to reject demands by corporate interests for unchecked data center expansion, and instead take action to address this looming threat to the public and climate progress. Those actions should be guided by the following principles:

• Prioritize affordable, renewable energy for the public above the speculative needs of technology corporations, and ensure data centers are not extending the life of coal and fracked gas, nor driving the build-out of new fossil fuel infrastructure, directly or indirectly.
• Ensure economic and energy policies related to data centers address corporate concentration, monopolization, and unfair competition in the energy, utility, and tech sectors.
• Guarantee that the public and utility ratepayers are not made to subsidize the wealthiest corporations in the world.
• Bring much-needed transparency into both the data center and utility sectors, so that the public, regulators, and lawmakers can make informed decisions that protect people and the planet.

Technological innovation has incredible potential for humans and the planet, but if tech giants and investor-owned utilities are allowed to call the shots, these special interests will follow only their short-term profit motives. If they are unchecked, we will expand dirty energy, stall our transition to renewable energy, and fail to meet our climate commitments.

As we submit this comment, coal plants that would have been retired are staying open, closed nuclear plants are being reopened for exclusive data center use, gas-fired power plants are expanding, and regular people are expected to pay increased prices for electricity – all to the benefit of the wealthiest technology corporations in the world. Data centers are also draining precious water resources, with a single data center potentially using several million gallons a day and threatening scarce local water supplies as drought conditions increase across the country.

While these tech corporations have made bold climate promises, they are underreporting climate impacts, walking back emissions reduction commitments, misleading the public on emissions reduction claims, lobbying against state-level climate legislation, and attempting to weaken global emissions reporting standards. Aggravating the problem, utility companies are prioritizing investor profits by investing in fossil fuels above renewable energy.

To make matters worse, states and counties are subsidizing data center expansion through tax breaks and utility deals, in order to compete for corporate investment that promises job creation but comes up far short. The last comprehensive study of data center subsidies revealed the public is giving away up to $1.95 million per permanent data center job. Similarly, property tax breaks for data centers mean that schools will have fewer resources than they would if the companies paid their fair share. Meanwhile, sweetheart utility deals and data center-driven energy grid expansions are predicted to increase the cost of energy for regular people.

Given these issues, we are deeply concerned that a handful of wealthy technology companies that stand to directly profit from fast-tracked data center infrastructure, including Amazon, Microsoft, Meta, OpenAI, Nvidia, and Google, are actively pressuring the Biden-Harris administration to take action that will guarantee the companies’ own power and influence far into the future. While tech executives argue that their investments in artificial intelligence are essential to national security and competitiveness, government officials should scrutinize these arguments. Tech companies have failed to offer concrete evidence that these investments will produce sufficient public benefits to justify substantial government intervention and funding, much less justify the threat to our renewable energy transition. Moreover, in an economy already plagued by monopolization and concentration, public handouts to corporations chasing increased market control is not good economic policy.

Read full comment: pdf

Submitted by:

Athena Coalition
350.org National
Chesapeake Climate Action Network
Citizens Action Coalition Indiana
Coalition to Protect Prince William County
Data & Society
Demand Progress Education Fund
Electronic Privacy Information Center
Fight for the Future
Free Press
Friends of the Earth
Good Jobs First
Institute for Local Self-Reliance
Kairos Action
Loudoun Wildlife Conservancy
MediaJustice
Nature Foward
Open Markets Institute
People’s Action Institute
Piedmont Environmental Council
PowerSwitch Action
Public Citizen
Sugarloaf Alliance