Build Your Own Testimony

The City of St. Louis Board of Public Service is holding a Conditional Use Permit hearing on March 19, 2026 at 8:30 AM for the proposed Armory/Goodwill hyperscale data center at 3728 Market Street — a 120 MW, 525,000 SF facility with up to 58 diesel generators, proposed for Midtown near dormitories, a children's hospital, and City Foundry STL.

You can submit written testimony opposing this project in minutes. Here's how:

HOW TO SUBMIT:

1. Choose 1–3 topics below that matter most to you.

2. For each topic, copy one or both paragraphs (they work alone or together).

3. Copy/Paste paragraph(s) in an email. Add your name, your connection to St. Louis, and any personal statement.

4. Send to: zoning@stlouis-mo.gov
Subject line: Opposition to CUP — 3728 Market St Data Center — Hearing 3/19

Deadline: Before the hearing on Wednesday, March 19, 2026, at 8:30 AM.

Choose Your Topics — 9 Reasons to Oppose

Pick the issues that resonate with you. Every email matters. Personal testimony from real St. Louis residents, students, workers, and neighbors carries weight.

Topic 1: Diesel Generators & Air Quality

Topic 2: Water Use & Cooling Systems

Topic 3: No Independent Environmental & Economic Impact Assessment

Topic 4: Community Consent & Proximity to Sensitive Sites

Topic 5: Utility Rate Impact on Residents

Topic 6: Property Tax Delinquency & Fiscal Irony

Topic 7: Transparency & NDAs

Topic 8: End User Disclosure

Topic 9: E-Waste & Electronic Waste Accountability

Topic 1: Diesel Generators & Air Quality

Why this matters: The application proposes up to 51–58 diesel backup generators adjacent to a children's hospital NICU, SLU dormitories housing 950+ students, and an open-air entertainment district — with engine tier, fuel type, and emissions controls still undecided.

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I am writing to oppose the conditional use permit for the proposed 120 MW hyperscale data center at 3728 Market Street. The applicant's own submission confirms the facility will rely on diesel-fueled backup generators — estimated at 51 or more units based on the site plan — while explicitly stating that 'final engine type, fuel selection, and emissions controls would be determined during detailed engineering.' This is not a minor detail to defer. At one hour of sequential testing per generator per month, the facility would log 51 or more generator-hours of diesel operation monthly — this is too close to the 210 hours typically mandated by MO DNR per year operating time — before a single emergency has occurred. The city is being asked to approve this use without any emissions modeling, any air permit analysis, or any confirmation that these generators will meet Tier 4 federal standards. That is not responsible land-use review.

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What makes this air quality concern especially urgent is the proximity of sensitive populations who were barely mentioned — or omitted entirely — from the applicant's community context analysis. The new Cardinal Glennon Children's Hospital, currently under construction at Chouteau and Grand, will house a NICU and pediatric ICU less than half a mile from this site. SLU's Spring Hall, a dormitory housing over 450 freshmen and sophomores, sits only ¼ mile away from the data center. Reinert Hall houses another 500+ students nearby at less than 1,000 feet away. City Foundry STL, a food and entertainment venue drawing thousands of visitors weekly, sits directly across the highway. Not one of these facilities was identified as a consulted party in the applicant's outreach documentation. I urge the Board to deny this permit until a full independent air quality assessment is completed and publicly reviewed. Imagine a family leaving the children’s hospital with their infant being given an asthma inhaler instead of a teddy bear, because that is where we are headed.

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Topic 2: Water Use & Cooling Systems

Why this matters: Key cooling decisions — including whether the facility will use a water-intensive evaporative system or a closed-loop design — have not been made. The City cannot evaluate the water impact of something that has not been designed.

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The City is being asked to approve a 525,000 square foot data center whose cooling and water systems have not been designed. In response to the Mayor's direct question about daily, weekly, monthly, and annual water consumption, the applicant stated only that 'exact daily, weekly, monthly, or annual consumption numbers cannot be provided without being speculative.' In response to a question about cooling aisle containment — a basic infrastructure design question — the applicant responded that the design 'has not yet been finalized.' A data center without a cooling system design is not a project ready for entitlement. It is a site plan with a nameplate and a promise. The Board of Public Service should not issue a conditional use permit for a facility whose most consequential infrastructure decisions remain open.

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St. Louis ratepayers and the Metropolitan St. Louis Sewer District bear the downstream consequences of poorly designed cooling systems. Evaporative cooling at this scale can consume millions of gallons of water daily, straining municipal supply in drought conditions and contributing to thermal discharge into the sewer system. The applicant gestures at 'closed-loop and air-cooled designs' but explicitly acknowledges these systems have not been selected. Without a binding commitment to specific water-efficient technologies — verified by an independent engineer and enforceable as a permit condition — residents have no assurance the project will deliver on its sustainability claims. I respectfully request this permit be denied or continued until complete cooling system specifications are submitted for public review.

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Topic 3: No Independent Environmental & Economic Impact Assessment

Why this matters: The MCE scorecard asks whether a publicly available, third-party environmental and economic impact report exists. For this proposal, the answer is no. All impact claims come from the applicant.

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The applicant has submitted a conditional use permit application for one of the largest proposed data centers in Missouri's history — 120 megawatts, 525,000 square feet, dozens of diesel generators — without a single independently prepared environmental or economic impact assessment. Every number in the record — the tax revenue projections, the jobs estimates, the utility impact claims, the water use assurances — comes from the applicant and has not been verified by any neutral party. When asked to show the methodology behind its $484.7 million ten-year tax revenue forecast, neither the applicant nor their consultant has responded with any further information. That is not sufficient diligence for a land use decision of this magnitude. The Board should require a third-party environmental and economic impact report as a condition of any further review, not as an afterthought.

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The absence of independent analysis is especially problematic given what the applicant has left unanswered. Fire suppression systems are 'not yet designed.' HVAC configuration is 'not yet finalized.' The end user — whose operational requirements will determine the facility's actual environmental footprint — has not been identified. The applicant is asking the City to approve a building envelope and then trust that the details will work out. Communities and school districts that stand to bear decades of noise, emissions, and infrastructure strain deserve better than a projections spreadsheet prepared by the developer. I urge the Board to table this application until a credible, independent review is complete and publicly available for comment.

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Topic 4: Community Consent & Proximity to Sensitive Sites

Why this matters: The application lists outreach to city agencies and a few institutional partners, but documented consent from the nearest residential and medical populations — SLU dormitories, One Foundry Way residents, and future Cardinal Glennon patients — is absent from the record.

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I am deeply concerned that the most directly affected communities were not meaningfully consulted in this application process. The applicant's outreach documentation identifies coordination with the Midtown Redevelopment Corporation, City departments, and organized labor — but makes no mention of the residents of One Foundry Way, the students housed in SLU's Spring Hall or Reinert Hall, or the staff and future patients of the Cardinal Glennon Children's Hospital under construction only .3 miles away. Spring Hall is only ¼ mile from this proposed facility. These are not distant stakeholders. They are the people who will live and sleep and receive medical care within a quarter mile of 51 diesel generators and industrial cooling infrastructure operating around the clock. Their absence from the outreach record is not a technicality — it is a fundamental failure of process.

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Meaningful community engagement is not a box to check; it is a precondition for sound land-use decisions. The MCE Dirty Data Center Scorecard asks whether a proposed facility has 'the consent of those who will live near the site.' Based on the record before the Board, the answer for this project is no. Two public sessions — one virtual, one in-person — were held. But these meetings were held for a different project. The application does not document that the populations closest to the physical impacts of this facility were reached, heard, or had their concerns incorporated into the project design. I urge the Board to deny this permit and require the applicant to conduct genuine, documented community engagement with nearby residents, students, and medical institutions before resubmitting.

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Topic 5: Utility Rate Impact on Residents

Why this matters: The applicant claims the project will not raise ratepayer bills. But Ameren's Large Load Tariff is new and untested at this scale, and the cost-shifting mechanisms have not been independently verified.

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The applicant asserts that the proposed 120 MW data center will not increase energy bills for St. Louis residents, citing Ameren's Large Load Tariff as a guarantee that infrastructure costs will be borne by the developer rather than existing customers. This claim deserves independent scrutiny before it is accepted as fact. The Large Load Tariff is a relatively new regulatory instrument, and its cost-isolation guarantees have not been stress-tested at the scale this facility would represent. A single customer consuming 120 megawatts would make this data center one of Ameren's largest individual accounts — comparable in load to an entire mid-sized city with 90,000 homes: the city of St. Louis only has 71,000 single family detached homes! The assurance that none of this demand will ripple into rate structures for residential and small commercial customers should be verified by an independent auditor, not simply accepted at the applicant's word.

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Beyond the tariff question, the applicant acknowledges it does not yet have an end user — meaning the actual load profile, operational schedule, and energy draw of this facility remain unknown. A facility designed for 120 MW but initially operating at lower capacity will still require infrastructure investment today based on maximum projected demand. Ratepayers across the Ameren territory, including St. Louis renters and homeowners already facing energy affordability challenges, deserve a clear and verified accounting of how those infrastructure investments are allocated before this permit is granted. I respectfully urge the Board to require an independent utility rate impact analysis before acting on this application.

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Topic 6: Property Tax Delinquency & Fiscal Irony

Why this matters: The City of St. Louis is simultaneously processing a conditional use permit for this property and suing the current owner in Circuit Court for $2.1 million in unpaid property taxes, with the parcel scheduled for tax sale.

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I want to draw the Board's attention to a remarkable and troubling fiscal irony embedded in this application. Court records filed in the Circuit Court for the City of St. Louis, Cause No. 2522-LT30071, show that the property at 3728 Market Street is currently subject to a delinquent tax lien foreclosure suit. As of January 31, 2025, the owner of record — GS 3728 Market Investors LLC — owed $2,141,753.48 in delinquent real estate taxes, penalties, interest, and fees covering tax years 2022, 2023, and 2024. The City is actively litigating to foreclose on this parcel and sell it at sheriff's sale. At the same time, the City's zoning apparatus is considering a conditional use permit application for the same site, filed by developers who propose to acquire the property. The City cannot credibly evaluate the fiscal benefits of a proposed development while simultaneously pursuing legal action to strip the existing owner of the property for nonpayment. COLLECT THE DELINQUENT TAXES BEFORE EVALUATING ANY PERMIT!

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This situation raises serious questions about the sequence of this approval process. The applicant projects $484.7 million in tax revenue over ten years — but the parcel that would generate that revenue is currently delinquent by over two million dollars and heading toward tax sale. Any responsible review of this project's fiscal claims must account for the current ownership situation, the terms under which the developers intend to acquire the property, and whether back taxes will be satisfied as a condition of any transfer or permit. The prospect of a City agency approving a conditional use permit on a property the City's own Collector of Revenue is trying to seize for nonpayment is not a small procedural quirk — it is a governance failure that should pause this process until the ownership and tax status of the parcel are fully resolved.

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Topic 7: Transparency & NDAs

Why this matters: The applicant acknowledges that certain project details are covered by non-disclosure agreements — including information about the prospective end user — the most important single fact needed to evaluate the project's actual environmental footprint.

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Transparency is not optional in a public land-use proceeding. The applicant's response to the Mayor's question about non-disclosure agreements acknowledges that 'certain project details are subject to customary non-disclosure agreements related to prospective end users, proprietary operational and security specifications, and commercial terms.' Translated plainly: the identity of the company that will actually operate this facility — and determine its power consumption, data use type, security posture, and operational schedule — is being withheld from the public record. We are being asked to evaluate the community impact of a 120 MW data center without knowing whether it will serve a social media platform, an AI training cluster, cryptocurrency mining, federal defense infrastructure, a massive surveillance apparatus, or something else entirely. Each of those use cases carries dramatically different implications for noise, emissions, security risks, and community character.

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The Missouri Sunshine Law and the public interest in open government demand that zoning decisions be made on the basis of complete and disclosed information. When an applicant invokes NDAs to shield the identity of its primary tenant from a conditional use permit proceeding, the Board is not able to make a fully informed decision — and neither is the public. The MCE scorecard asks simply: 'Commit to full transparency by not using any NDAs?' For this project, the answer is no. That alone should give the Board pause. I urge the Board to require full disclosure of the end user's identity and operational intent as a minimum condition before any permit is granted, and to table this application until that information is part of the public record.

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Topic 8: End User Disclosure

Why this matters: The applicant has not identified an end user. The entire environmental and economic profile of a data center depends on who operates it and for what purpose — information that is entirely absent from this application.

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The application before the Board asks the City to approve a 525,000 square foot industrial facility with 120 megawatts of power capacity without disclosing who will actually use it. The applicant states plainly: 'A specific end user has not yet been identified. Identification of an end user and confirmation of specific operational uses would occur following completion of the entitlement process.' This is backwards. The conditional use permit process exists precisely to evaluate whether a proposed use is compatible with its surroundings. The 'use' of a data center is not defined by its square footage or its precast concrete facade — it is defined by the tenant's workload. Artificial intelligence training, cryptocurrency mining, cloud backup, federal government computing, and social media operations each carry distinct power draw profiles, security classifications, noise levels, and workforce compositions. The Board cannot evaluate compatibility with the surrounding Midtown neighborhood without knowing what this building will actually do.

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The applicant argues that end users are routinely identified after entitlement in the data center industry. That may be common practice in greenfield industrial parks, but it is not appropriate for a facility proposed in a dense urban context adjacent to dormitories, a children's hospital, an entertainment district, and one of Missouri's major research universities. Standard industry practice is not the same as adequate community protection. If the City grants this permit without an identified end user, it will have made a permanent land-use decision based on hypothetical impacts — while binding the surrounding neighborhood to decades of consequences it was never able to specifically evaluate. I urge the Board to require end user identification before this permit advances.

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Topic 9: E-Waste & Electronic Waste Accountability

Why this matters: The applicant defers all e-waste responsibility to a future, unnamed end user — leaving the City with no enforceable commitment regarding the handling and disposal of decommissioned servers, hardware, and hazardous materials.

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The MCE Dirty Data Center Scorecard asks whether a proposed facility commits to recycling all e-waste. For this project, the answer is a deferral: 'Specific protocols for handling and disposing of electronic waste, such as decommissioned servers and hardware, would be determined by the facility's end user or operator.' This response is inadequate. A 525,000 square foot data center will cycle through significant volumes of servers, batteries, cooling equipment, and circuit boards over its operational lifespan — materials that often contain lead, mercury, cadmium, and other hazardous substances regulated under Missouri and federal environmental law. Leaving disposal responsibility to an unidentified future tenant, with no enforceable protocol in the permit record, means the City has no mechanism to hold anyone accountable if e-waste ends up in landfills or improperly handled.

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The environmental justice implications of this gap fall disproportionately on communities nearest to the facility and to the downstream waste facilities where improperly managed e-waste tends to end up. St. Louis has a well-documented history of environmental hazards concentrated in low-income and majority-Black neighborhoods. Approving this data center without binding, enforceable e-waste management requirements — requiring certified recycling vendors, chain-of-custody documentation, and annual public reporting — would be a failure to apply the lessons of that history. I urge the Board to require the applicant to submit a comprehensive e-waste management plan, with specific vendor commitments and third-party auditing requirements, as a non-negotiable condition of any conditional use permit.