Mayor Mills and Members of Brighton City Council, This is a follow-up to the questions previously submitted by the Brighton Data Center Transparency Project regarding Project Silo / the Willard Property data-center proposal. Since sending those questions, I have continued reviewing the City’s own planning documents, Project Silo records, Brighton land-use policy, and Brighton’s identified employment and industrial development areas. That review raises an additional and very important question: **Why was this particular location selected for Project Silo, and what alternative locations were evaluated before a large data-center campus was proposed between existing and developing residential communities?** This question is particularly important in light of Brighton’s own adopted planning guidance. Brighton’s current Long Range Planning page states that the **2016 Be Brighton Comprehensive Plan remains in effect until the new Comprehensive Plan is adopted.** That plan states that industrial uses are generally not compatible with residential uses and directs higher-impact industrial activity away from residential areas and toward locations with appropriate transportation and supporting infrastructure. Brighton’s current Land Use and Development Code follows the same general planning principle. Its I-2 Heavy Industrial district recognizes that high-intensity industrial uses may be incompatible with residential or commercial activity because of their scale, operational impacts, transportation needs and supporting infrastructure requirements. Project Silo is not a conventional commercial building. The concept documents depict an eight-building data-center campus with individual buildings of approximately 310,000 to 315,400 square feet, together with a 230 kV transmission extension, a switching station, customer substation and multiple transformers identified at 200 MVA each. Brighton’s own January 2025 pre-application records describe several approximately 300,000-square-foot buildings, a switching station and substation. Those same records state that portions of N. 50th Avenue and WCR 4 would need to be constructed, that a traffic-impact study would be required, and that Brighton and Lochbuie would need to coordinate on roadway design and long-term maintenance. Those records also show that significant utility questions were unresolved. City staff raised concerns regarding cooling-system technology and water demand, discussed potential wastewater connection into Lochbuie’s system, noted that flow data was not available for part of that network at the time, considered multiple water-line options, and required a water-resources report. The applicant’s July 2025 material further states that off-site water, sanitary sewer and storm-sewer connections would need to be routed through property not owned by the development. The later PAC records also require traffic analysis, roadway design, pavement analysis, lighting plans and consideration of underground conduit, while noting that additional discussion of surrounding water and sanitary-sewer infrastructure was still needed. This leads to a basic site-selection question: **If a project requires extraordinary new electrical, road, water, sewer, telecommunications and emergency-response infrastructure, why place it in a location where substantial portions of that infrastructure must first be created or extended, particularly when Brighton already identifies other areas for industrial and employment development?** Brighton itself currently promotes several areas that should at least be evaluated objectively. 1. **North Brighton Employment Area / Energy Corridor.** Brighton’s Urban Renewal Authority describes this as part of an approximately 3,000-acre area south of the Vestas campus intended for sustainable industrial and advanced-manufacturing development. Brighton specifically advertises direct Highway 85 access, industrial rail and utility service there. 2. **The I-76 / Bromley Industrial Corridor.** Brighton describes 76 Commerce Center as a 122-acre industrial development with direct access to I-76. Brighton recently announced that Crusoe, an AI-infrastructure company, is locating a 352,000-square-foot manufacturing facility at 22600 E. I-76 Frontage Road, describing the location as part of Brighton’s established I-76 industrial corridor. 3. **South Brighton Employment Area / Adams Crossing.** Brighton identifies the I-76/E-470 area as a major employment center. Because this area includes mixed uses, any potential data-center location there would still need appropriate separation from existing and planned residences, but it demonstrates that Brighton has designated employment areas associated with major regional transportation infrastructure. I am **not asserting that any of these locations is presently available, electrically feasible or appropriate for Project Silo.** That is precisely the point. I am asking whether Brighton and the applicant conducted an objective alternative-site analysis before advancing the WCR 4 site. Please provide written answers to the following: **Was an alternative-site analysis conducted for Project Silo?** If so, please identify every site or general area considered and provide the analysis, scoring criteria and reasons each alternative was accepted or rejected. **Who initially selected the Willard/WCR 4 property as the preferred location?** Was it selected by the landowner, Alberta Development Partners, a prospective end user, a site-selection consultant, Brighton Economic Development, a utility, or another party? **Did Brighton Economic Development present or discuss alternative Brighton sites with the applicant?** If yes, please identify those locations and provide the related correspondence or meeting records. **Was the North Brighton Employment Area / Energy Corridor evaluated?** If not, why not? **Was the I-76/Bromley industrial corridor evaluated?** If not, why not? **Were other existing industrial or employment-designated areas within Brighton evaluated?** If not, why not? **What site-selection criteria were actually used?** Please identify how the current WCR 4 site was evaluated for residential separation, schools, road capacity, heavy-equipment access, transmission access, electrical capacity, fiber diversity, water availability, wastewater capacity, fire protection, drainage, noise, light pollution, generator emissions and public infrastructure costs. **What is the current distance between proposed Project Silo infrastructure and the nearest existing and approved future residences?** Please provide distances not only from building walls, but from cooling equipment, generator areas, electrical substations, switching equipment and other continuous or intermittent noise-producing infrastructure. **What alternative-site comparison was performed specifically for noise and light impacts?** A 24-hour data-center campus is fundamentally different from a warehouse that closes at night. Please provide any modeled nighttime noise, low-frequency or tonal-noise analysis and photometric analysis available for the WCR 4 site. **What telecommunications infrastructure currently exists at the WCR 4 location?** The Project Silo documents discuss underground conduit but do not, in the records we have received, establish the final fiber architecture required for an eight-building data-center campus. Please identify the proposed carriers, fiber routes, interconnection locations, required conduit construction, route diversity and responsibility for paying for that infrastructure. **Has the proposed electrical interconnection point been determined?** The concept materials depict substantial 230 kV infrastructure. Please identify the proposed interconnection location, utility, requested or anticipated MW load, transmission construction required, easements required and responsibility for associated costs. **What is the total infrastructure cost attributable to choosing the WCR 4 site?** Please include roads, intersections, water, wastewater, drainage, electrical transmission, substations, telecommunications conduit, fire/emergency infrastructure and other public improvements. Please then identify which costs will be borne entirely by the developer and which could ultimately be borne by Brighton, Lochbuie, Weld County, utilities, ratepayers or taxpayers. I am also asking Council to consider a simple, transparent exercise before any final discretionary decision concerning Project Silo: **Publish a comparative site analysis using the same criteria for the WCR 4 property and Brighton’s established industrial/employment areas.** The criteria should include electrical capacity and interconnection cost; fiber availability and route diversity; water and wastewater capacity; road and heavy-haul access; distance from existing and approved residential development; distance from schools; noise; lighting; generator and air-quality impacts; emergency-response capacity; environmental constraints; infrastructure costs; tax revenue; permanent employment; and construction impacts. If WCR 4 is demonstrably the strongest location after that analysis, the public will be able to see the evidence supporting that conclusion. If another location performs substantially better, that is information the developer, City Council and community should have **before irreversible land-use and infrastructure decisions are made.** This is not a request to relocate Project Silo based on speculation. It is a request to establish whether this location was selected through a transparent, evidence-based siting process and whether reasonable alternatives were evaluated. Finally, please preserve all correspondence, meeting records, presentations, site-selection materials, scoring documents, economic-development communications and communications with the applicant or prospective end user concerning alternative locations for Project Silo. If no alternative-site analysis exists, please state that plainly in writing. Thank you, **Brighton Data Center Transparency Project** Community-led research, public records & accountability Brighton • Lochbuie • Weld County, Colorado Independent community project. 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