Comments Submitted to the U.S. Army Corps of Engineers Regarding Proposed Data Center Project

April 27, 2026

Dear Mr. Gala/Corps of Engineers: 

Attached hereto are comments that I wish to submit to the U.S. Army Corps of Engineers ("the Corps") regarding the captioned permit application. 

I understand that the applicant, Mr. Michael Montfort, of Willowbend Capital, LLC based in Washington, D.C., has submitted an application for a Clean Water Act Section 404 permit that would authorize the dredging and/or filling of approximately 16.8 acres of wetlands and approximately 6,419 linear feet of streams in or about Sections 19, 20, 29 and 30 of Township 2 North, Range 11 West, Pulaski County, Arkansas. The purpose of this project would be the construction of a Light Industrial Complex of five buildings totaling approximately 1.43 million square feet, which would be used as a Data Center. That Center would "likely draw more than 100 megawatts of power," which I assume is electric power. This will be referred to herein as "the Project."

The term "Data Center" is not defined in the Revised Public Notice issued by the Corps. However, I also understand from sources other than the Public Notice that the project will ultimately be used by Google, Inc., a well-known provider of internet and other data and information services, which provides some general information relating to the use to which the property will be put. The comments contained herein are not dependent so much upon the individual user of the property as they are on the use of the property as a Data Center, as the term is commonly understood. 

Data Centers, and their common characteristics, have been in the public consciousness for a relatively short period of time, although the recent publicity regarding them has been intense. Several problems that they appear to have in common are: (i) they generate a considerable amount of irritating and continuous noise; (ii) they consume copious amount of water; and (iii) they consume extraordinary amounts of electricity. Although not frequently mentioned, they frequently consume large areas of land, which is certainly the case in this particular Project and others mentioned for development in Arkansas.

As the Corps points out in its Revised Public Notice, the evaluation of the application should include the direct, indirect and cumulative impacts of the project on the public interest and on the area that is affected, directly or indirectly. While the Project as described in the Revised Public Notice is obviously very large, the Notice mentions a few of the other components of the Project that will have far-reaching and destructive impacts that will be discussed herein. All of these characteristics lead to the conclusion that this is a huge Project requiring huge amounts of water and electricity, and whose operations create serious consequences that have the potential to wreak havoc, not only on the Project Site and the environment and wildlife in the vicinity of the Site, but also on the daily lives of the citizens in the City of Little Rock and Central Arkansas.

These effects must also be considered in conjunction with other "Data Center" sites that are being discussed and planned for construction in central Arkansas. The planned development of numerous such Centers in the area could cumulatively be devastating to human health and the environment, including the economy of the area, particularly for people of low income and fragile health.

The Project Will Consume Amounts of Electricity That Will Threaten Its Availability to the Public

The Corps' Revised Public Notice noted that the proposed facility "would likely draw more than 100 megawatts of power." That power is proposed to be obtained from Entergy, a major electrical generator in Arkansas.

According to its website, Entergy owns or operates approximately 24,000 megawatts of generating capacity, consisting of natural gas, oil, nuclear, solar, hydroelectric and coal power plants. That power is distributed to more than 3 million customers consisting of households, commercial and industrial facilities located in Arkansas, Louisiana, Mississippi and Texas.

Pulaski County, Arkansas, which includes the City of Little Rock, has a total annual electricity consumption of over 6.7 million megawatt hours (MWh). Pulaski County contains roughly 400,000 residents. Based on these numbers, it appears that Pulaski County alone consumes approximately one-fourth (1/4th) of the electrical generating capacity of Entergy. Nationally, a study from the Lawerence Berkeley National Laboratory found that data centers could consume up to 12% of all U.S. electricity consumption by 2028.

The addition of the Data Center that is the subject of the proposed permit would add another 100 megawatts of demand for Entergy's electricity, raising the very reasonable and extremely serious question of whether there is sufficient energy availability to serve all of the existing and future customers with that indispensable power source?

This is a particularly relevant question today for a number of reasons: 

1. A number of existing older power generation plants - particularly older, less-efficient and heavily-polluting coal-fired power plants are being phased out or are scheduled for closing, either by regulatory requirements or court decrees. Those closures will remove a portion of the current capacity from the electrical market, and will exacerbate the problem of how to meet a demand for electricity that is rapidly expanding due, in part, not only to the enormous appetite of data centers for electricity, but also of the demands made by increasing population centers.

In April 2025, Jim Matheson, Chief Executive Officer of the National Rural Electric Cooperatives Association, testified before a committee of the U.S. House of Representatives that "critical electric generation resources are being retired faster than they can be reliably replaced," and that "electric reliability is non-negotiable," in that “a resilient, reliable and affordable electric grid is... the cornerstone of our nation's economy and energy security."

More new data centers are being constructed in Northern Virginia and Texas than anywhere in the country. Mr. David Schleicher, the President and CEO of the Northern Virginia Electric Cooperative, has stated that such data centers will be "engines of growth for electricity providers," but will also pose "major reliability risks." Those centers "are having a huge impact on power consumption," according to Mr. Schleicher, but he noted that "data centers can be built in 18 months well ahead of the four-year or longer lead times for new substation equipment."

The country is fascinated today by the concept of artificial intelligence (“AI”), and the possibilities that it holds for making our lives better - and in some ways, worse. We are told that if we do not rush to develop AI to its fullest potential, that other nations will do so before we (the United States) do, and that failure will affect our national security. While there may be some truth to that, those who advocate an unquestioning rush to AI development are foolishly ignoring the consequences of that hasty action.

It will not affect our national security for the Corps of Engineers to take the time to fully explore the direct, indirect and cumulative impacts of the application of a Google-substitute for the permit. The concerns of the citizens who reside in central Arkansas, in particular, who live here in part for the natural environment that it offers, should not be ignored or given cursory consideration because an economic powerhouse such as Google wants to construct a 1.43 million square-foot complex, along with the accompanying structures (substation/switching station, power line transmission corridors, etc.) that will profoundly impact the environment.

To rush in granting a permit for the construction of this Project, when there is no indication in the documents that have been made available that there is ample electricity to reliably serve the Project as well as existing and future customers, would be foolhardy, and invite blackouts or brownouts and other issues of reliability of service.

And finally, there is the issue of who is going to pay for the costs of generation of the electricity necessary for the data center and the other customers of Entergy? Based upon current information, it appears that the citizens of Arkansas who happen to be customers of Entergy will have the obligation to contribute to the costs of building the additional generating capacity needed for the data center. That may be a subject about which there will be further controversy, and it should be resolved before any permit is issued for the Project.

The Project Could Potentially Threaten the State's Water Supplies

There is virtually no data available in the Revised Public Notice about the source of waters that will undoubtedly be required for the Project in its operations, so my comments on the consequences of the Project's water usage will necessarily be general.

Only 3% of Earth's water is freshwater, and only 0.5% of all water is accessible and safe for human consumption. Arkansas has historically been blessed with a substantial quantity of high-quality water from rainfall and groundwater, but that is rapidly changing with the consequences of population growth, industrial and agricultural pollution and climate change. While we have taken for granted an abundant and never-ending supply of water for drinking, domestic and industrial use, we must adjust that thinking, and be more protective of activities that affect our surface and ground water sources.

That statement is supported by a presentation made by the Arkansas Department of Agriculture - Natural Resources Division to the Arkansas Environmental Federation at a Water Seminar in April of this year. That presentation, based upon studies conducted by nationally-recognized consultants, 20 years of groundwater and surface water data, and data from "thousands of surface water monitoring stations and wells," found that there were "increasing trends in chloride and total dissolved solids observed in urbanized watersheds, declining dissolved oxygen levels detected in nutrient-enriched systems, seasonable variability significant for temperature and dissolved oxygen; and that approximately one-half of the Arkansas Department of Environmental Quality's assessed stream miles are listed on the agency's 2022 Clean Water Act Section 303(d) list of distressed water bodies.

Large data centers are a concern because they can consume up to 5 million gallons of water per day. That is equivalent to the water use of a town populated by 10,000 to 50,000 people. Again, using Northern Virginia,- considered the world capital for data centers with over 300 operational data centers,- as an example: all data centers in Northern Virginia consumed close to 2 billion gallons of water in 2023, a 63% increase from 2019. Loudoun County, with approximately 200 operational data centers, used around 900 million gallons of water in 2023. Regardless of whether the waters are from surface or groundwaters, those quantities are breathtaking, and would have a substantial impact on Arkansas' drinking water sources.

From an indirect impact perspective, a significant portion of data center water usage originates from the power facilities where they obtain their energy. Because 56% of the electricity used to power data centers nationwide comes from fossil fuels, a significant portion of data center water consumption is derived from steam-generating power plants. In addition, chip manufacturers use very large amounts of water in manufacturing their products used in data centers. Thus, data centers have a huge impact on the water resources of our state and country.

The Data Center Can Cause Noise Harmful to Humans and Wildlife

According to the American Speech-Language-Hearing Association, safe sound levels are 70 A-weighted decibels (dBA) or lower. Exposure to sounds 85 dBA and above is considered to be harmful to hearing.

Data centers generate significant and continuous noise pollution, often described as a low-frequency hum or whine, due to the multitude of intensive cooling systems, fans, and emergency generators. These facilities can produce noise up to 100 - 110 dBA.

HVAC systems are necessary to control a data center's temperature, humidity and airflow. Most of the system is inside the facility, while some HVAC fans are outside. With the rise in AI and data storage demand, servers consume more energy by the day. Temperatures rise quicker when servers have large workloads, so HVAC systems continuously work at an increased rate to cool the servers and aisles.

HVAC fans in data centers generate noise levels ranging from 55 to 85 dBA. This noise contributes to the loud humming and buzzing sounds that people commonly associate with data centers. In addition, the constant high-power drawdown of electricity into the centers causes a low-frequency humming sound, similar to HVAC fans.

Noise levels can reach 96 dBA inside a data center, according to C&C Technology Group. Exposure over half an hour at this level could damage hearing. Noise levels are higher inside a data center because of the closed-in area that echoes hums and buzzes from server fans, HVAC systems, and other running equipment and hardware. Data center staff who experience prolonged exposure to high noise levels may suffer from hearing damage, decreased productivity and increased stress.

Noise at data centers is also contributed to by generators. A data center that gets its electricity directly from a producer such as Entergy will, nevertheless, also install numerous emergency generators to allow operations to continue in the event of a failure. Smaller diesel generators reportedly reach 85 decibels, levels that can harm hearing. Larger industrial generator units can approach 100 decibels - equivalent to a motorcycle or jackhammer.

Residents living near data centers are condemned to hearing the never-ending and irritating noise generated by the data center, sometimes audible up to two miles away, depending on the surroundings and topography. People living near data centers report headaches, stress, nausea, and, in severe cases, severe sleep deprivation due to the constant low-frequency hum. Long-term exposure to these noises may cause symptoms similar to vibroacoustic disease, including headaches and increased stress markers. Lack of sleep and stress can result in anxiety, cognitive impairment and cardiovascular risks. In more extreme cases, noise pollution can cause tinnitus and hearing loss.

It should not be overlooked that the constant noise, along with artificial lighting, can negatively impact wildlife in nearby conservation areas. In some ways, they are more sensitive than humans to noise, frequently having more acute hearing, and being more reactive to it. Similar to how boat engines and sonar equipment affect marine life, noise pollution on land disrupts animal communication and forces them to migrate from the area, or causes erratic behavior.

The Data Center Will Generate Air Pollution And Contribute to Noise Pollution

Data centers need a constant and reliable power supply. While the Data Center that is the subject of the permit application will apparently obtain its power from Entergy, Google will undoubtedly install and use diesel generators for emergency backup, and with the size of the proposed facility, there will be a substantial number of those generators. Even with occasional use, those generators come with climate and health risks.

Diesel-fueled backup generators release harmful air pollutants, including fine particulate matter (PM2.5) and nitrogen oxides (NOx), linked to respiratory disease, heart disease, asthma and other serious health risks. Although these generators are only used during emergencies, they can have outsized health impacts, emitting 200 to 600 times more nitrogen oxides than natural gas plants. One analysis in Virginia estimated that even limited backup generator use could be associated with nearly $300 million in annual public health costs and 14,000 asthma-related health impacts across multiple state.

The Application Would Destroy a Large Area of Wetlands

The following are comments contained in a Memorandum dated May 16, 2022, From Steven Patterson, Ph.D., Restoration Ecologist, to the Arkansas Division of Environmental Quality (ADEQ) regarding the history and value of wetlands and their current condition in Arkansas, which is highly relevant to the present application:

Wetlands were once seen by many as waste areas, with little value. Consequently, over the past 200 years, approximately half of the wetlands of the United States have been lost, primarily through filling, dredging, or draining (Dahl 1990). In Arkansas, it is estimated that wetland loss has been even greater than the national average, with over 70% of wetlands in the state lost (Dahl 1990).

Two hundred years ago there were approximately 9.8 million acres of wetlands within the boundaries of what would become the State of Arkansas, almost 30% of the total surface area of the state. By the mid 1980's the area of wetlands had been reduced to only 2.8 million acres (Dahl 1990). While the greatest losses occurred in the Arkansas Delta region, significant wetland loss has also occurred along the Arkansas River, in areas like the current project. Future declines will likely be magnified by the effects of climate and land use/land cover change.

In recent decades the value of wetlands has become increasingly evident, leading to laws to protect them. Wetlands play an important role in flood control, nutrient cycling and improving water quality; they provide essential wildlife habitat and provide nutrients that support fishing. In addition, they provide opportunities for recreational use and nature study and appreciation. More recently their role in long term carbon storage has been recognized. Federal law, Section 404 of the Clean Water Act, recognizes the importance of wetlands and the consequences of their loss, and requires permits from the US Army Corps of Engineers to impact wetlands through the discharge of dredge or fill materials.

The area that is now Arkansas began losing wetlands shortly after the arrival of European settlers and farmers who cleared the bottomland hardwoods and wetlands for farming. By 1993, more than 90% of Arkansas' original bottomland forested wetlands had been lost. Arkansas has lost more wetland acres than any inland State in the Nation. And, even though the rate of wetland loss has declined in recent years, Arkansas continues to lose wetlands. (Source, National Water Summary - Wetlands Resources: ARKANSAS, U.S. Geological Survey, Water-Supply Paper 2425)

The application under consideration by the Corps would involve the direct and immediate loss of some 17 or more acres of wetlands, and over 6,000 linear feet of streams which, by itself, does not seem like a lot, but it has to be viewed in conjunction with hundreds of other projects and activities that have filled or propose to fill wetlands and streams, particularly in this area of industrial development. The wetlands involved in this particular case are the Fouche Creek Wetlands, which is considered one of the largest urban wetlands in the U.S., draining some 108,000 acres.

Substantial volumes of wetlands and streams have been lost in this same area in recent years due to other large developments in the Little Rock Port area. The Corps must take into consideration the cumulative impacts of those other developments on the area wetlands, and the effects of the loss of those wetlands on the area environment.

Indirect and Cumulative Impacts Should Be Carefully Studied

It is frequently the case that some of the most consequential impacts of a project - particularly one as large as this - are those that are indirect or cumulative.

"Indirect impacts" are generally considered to be those that are a consequence of an action, policy, or project that occurs later in time or farther removed in distance than the direct, immediate effect. The indirect impacts of data centers extend far beyond their physical walls, creating significant environmental, social, and economic consequences for surrounding communities and infrastructure.

A good example of an indirect impact of the proposed project is the necessity and extent of roads, power lines, pipelines and other services that have to be installed to and from the Data Center for its construction and operations. Obviously, power lines will have to be installed from the Entergy electrical generation plant to the Data Center, which requires Entergy to acquire rights-of-way through private and/or public property.

Those rights-of-way will be approximately 100 feet in width, and must be cleared of any vegetation. That could destroy hundreds of acres of trees and other vegetation or structures. After clearing, the rights-of-way must be maintained vegetation free, which often requires the use of herbicides sprayed on the area in the right-of-way. The impact of clearing of timber, and use of herbicides should be carefully considered.

"Cumulative impacts" are the combined, incremental effects of separate human activities and natural processes over time, which may be individually minor but collectively significant to human, environmental and community health.

In this case, a major possible cumulative effect that should be seriously considered is that there are a number of data centers being proposed for development in the central Arkansas area in addition to the one that has applied for this 404 permit. One of the other centers is proposed to be located a relatively short distance from the subject facility. The addition of two or three large data center facilities in central Arkansas would undoubtedly have major, and potentially catastrophic, cumulative effects on the availability of electrical power, water and other commonly used resources in the area.

These are only examples of indirect and cumulative effects. Studies should be conducted of all of such effects that are conceivable, and the results of such studies released to the public for comment.

Any Permit Should Not Be Issued Until All Preconditions To The Construction of the Project Have Been Fulfilled

As the Corps' Revised Public Notice states: "The DA permit may not be issued pending the conclusion of the [Environmental Protection Agency] Administrator's determination of effects [of the Project] on neighboring jurisdictions. The Notice also acknowledges that the Notice is "based on information furnished by the applicant," and "has not been verified or evaluated to ensure compliance with laws and regulations governing the regulatory program.”

The scope of the proposed Project is very large and its effects could have far- reaching and permanent impacts on the citizens of Arkansas and their environment. Not only should the Corps engage in a comprehensive and exhaustive inquiry into the accuracy of the applicant's application, and the Project's direct, indirect and cumulative effects, but it should not issue any permit that would allow the applicant to conduct any activities on the site until all other preconditions (i.e., permits issued by other agencies necessary for the Project to proceed to development) have been obtained.

Request for Public Hearing

I request that a public hearing be held on this permit application considering the importance of the subject matter of the application to the public and environment of central Arkansas. I also request to be notified of any notices or actions taken by the Corps of Engineers on this matter.

I appreciate the opportunity to submit these comments and look forward to a constructive dialogue with the Corps on them and others. Please acknowledge receipt of these comments for my records.