Re: Opposition to Proposed Data Center Moratorium Legislation (S.10642/A.11560, S.9182-B/A.10852-B, S.10546/A.9297-A, and S.9144-A/A.10141-A)

As Business Manager and Financial Secretary of the International Brotherhood of Electrical Workers (IBEW) Local 43, representing highly skilled electrical workers throughout Central New York, I write to respectfully urge your opposition to legislation that would impose a moratorium on or significantly restrict data center development in New York State.

Our members build, maintain, and operate the electrical infrastructure that powers homes, businesses, hospitals, schools, public services, and emerging technologies. We understand the importance of grid reliability, environmental stewardship, and responsible planning because we are the workforce tasked with delivering and maintaining these critical systems every day.

We recognize that large scale data center projects raise important questions regarding electric demand, infrastructure investment, water use, environmental impacts, and community benefits. However, the proposed moratorium bills are not the solution. New York already possesses robust environmental review processes, permitting requirements, utility oversight, and local zoning authority capable of evaluating projects on a case-by-case basis. Rather than improving outcomes, these bills risk driving billions of dollars in investment, thousands of skilled jobs, and critical infrastructure development to competing states.

Several arguments have been made in support of these proposals, and we believe it is important to address them directly.

One concern is that large data centers will require significant utility infrastructure investments that could be paid for by residential and small business ratepayers. While cost shifting is a legitimate concern, the answer is not to stop development altogether. The proper approach is to require data centers to fund the infrastructure needed to serve their load through direct investment, appropriate rate structures, financial guarantees, and Public Service Commission oversight. New York can ensure that costs are allocated fairly without halting projects that would otherwise strengthen and modernize the electric grid.

Supporters of the moratorium have also cited concerns about grid reliability and referenced events such as the Texas power crisis during Winter Storm Uri. However, that event was the result of underinvestment, inadequate maintenance, and insufficient system hardening not the existence of large industrial customers. A moratorium does not strengthen the grid, add utility workers, modernize substations, or improve reliability. The better solution is continued investment in infrastructure, workforce development, training, and system upgrades that allow the grid to meet future demand safely and reliably.

Others argue that data centers threaten New York's climate goals by increasing electrical demand. This argument overlooks the reality that large, predictable electrical loads can help drive investment in renewable energy, transmission infrastructure, energy storage, and grid modernization. Data centers create long-term demand that often make these investments economically viable. Preventing data center development in New York will not eliminate the demand for these services; it will simply push development to states with less aggressive environmental standards and a greater reliance on fossil fuels.

Water consumption is another frequently cited concern. Water use should absolutely be evaluated and addressed where appropriate. However, New York's environmental review process already requires extensive analysis of water impacts. A statewide moratorium applies the same restrictions to every proposed project regardless of location or circumstances. Local conditions matter, and existing permitting processes provide the tools needed to evaluate those impacts responsibly.

Critics also argue that data centers consume substantial amounts of electricity while creating few permanent onsite jobs. This assessment ignores the broader economic impact associated with these projects. The electrical infrastructure required to support data centers including substations, transmission lines, distribution systems, protection equipment, energy storage facilities, and renewable energy connections creates years of construction work and long-term utility employment. These are prevailing wage careers that support families, strengthen local economies, and create apprenticeship opportunities for future generations.

Some supporters of the moratorium have suggested that a temporary pause is necessary to allow regulators and policymakers time to study the issue. While further study is certainly reasonable, a moratorium sends a damaging signal to investors and developers that New York is closed for business. Such actions often create unintended consequences, encouraging projects to rush through development before restrictions take effect while simultaneously driving future investment to competing states.

We also support the concept of meaningful community benefits. However, those benefits should be structured in ways that strengthen local infrastructure, improve reliability, support workforce development, and create lasting economic opportunities. Investments in grid hardening, substations, energy storage, transmission upgrades, and workforce training provide far greater long-term value to host communities than policies that simply discourage development.

Finally, while accountability for public incentives is important, New York should not eliminate economic development tools that help attract major investments and create family sustaining careers. Public incentives should be tied to strong labor standards, prevailing wage requirements, workforce development commitments, and measurable community benefits not abandoned altogether.

Data centers have become critical infrastructure supporting artificial intelligence, cloud computing, healthcare systems, telecommunications, financial services, research institutions, and countless other technologies that drive today's economy. New York has an opportunity to shape this growth responsibly while creating thousands of union jobs, strengthening its electric grid, and expanding its tax base.

The choice before policymakers is not between unrestricted development and a moratorium. The choice is between smart regulation that protects communities while encouraging responsible investment, and broad restrictions that drive jobs, infrastructure investment, and economic opportunity elsewhere.

Our members live in communities affected by these decisions. They build the grid, maintain it through storms, and keep it operating every day. We support responsible oversight, environmental accountability, and fair treatment for ratepayers. What we cannot support is legislation that blocks investment, delays infrastructure improvements, and sends good-paying union jobs to other states without delivering meaningful benefits to New Yorkers.

For these reasons, I respectfully urge you to oppose the proposed data center moratorium legislation and instead pursue policies that promote responsible development, strong labor standards, reliable infrastructure, environmental stewardship, and economic growth.

Thank you for your consideration. I would welcome the opportunity to discuss this matter further and provide the perspective of the skilled electrical workforce that will be responsible for building and maintaining this critical infrastructure for decades to come.