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Terri Harding
<br />July 14, 2026
<br />Page 4
<br />My client requests confirmation that the following uses are permitted in the E-1 zone, whether as
<br />expressly listed permitted uses or as uses properly classified within the E-1 permitted use
<br />categories:
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<br />• Data Center. For purposes of this request, “Data Center” means a facility used primarily
<br />for the operation of computer servers, network equipment, data storage systems,
<br />telecommunications/fiber infrastructure, cloud-computing infrastructure, artificial-
<br />intelligence or high-performance computing infrastructure, and related information-
<br />technology systems used to store, process, manage, transmit, exchange, and secure digital
<br />information.
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<br />EC 9.1080 provides that zone verification is used to determine whether a proposed
<br />building or land use activity “would be a permitted use or be subject to land use
<br />application approval or special standards applicable to the category of use and the zone of
<br />the subject property.” For uses not specifically identified on the allowed-use list, EC
<br />9.1080 directs the Planning and Development Director to determine whether the use is
<br />permitted, conditionally permitted, prohibited, or subject to land use review based on “the
<br />requirements applicable to the zone, applicable standards, and on the operating
<br />characteristics of the proposed use, building bulk and size, parking demand, and traffic
<br />generation.”
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<br />Under that standard, Data Centers are best understood as Information Technology
<br />Services uses, not as sui generis industrial or utility uses. Table EC 9.2450 permits
<br />Information Technology Services uses in the E-1 zone, including Computer Networking,
<br />Internet and Web Site, Software Development, and E-commerce, including business-to-
<br />business services and related technical-support functions. A modern data center is the
<br />physical infrastructure through which those information-technology services are
<br />delivered. Its core function is to operate servers, network systems, storage systems,
<br />telecommunications/fiber infrastructure, cloud-computing systems, and related platforms
<br />that process, store, manage, transmit, exchange, and secure digital information for
<br />enterprise, cloud, colocation, managed-services, cybersecurity, artificial-intelligence,
<br />high-performance computing, and other business-to-business technology users. Those
<br />activities are squarely within the computer networking, internet/web, software, e-
<br />commerce, and technical-support activities listed as permitted E-1 Information
<br />Technology Services uses.
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<br />This classification is also consistent with the structure and purpose of the E-1 zone. EC
<br />9.2400 describes the E-1 Campus Employment Zone as providing large areas for “light
<br />industrial and office-based scientific, medical, research and development, or other
<br />professional firms to locate in a campus-like setting.” The E-1 zone is therefore intended
<br />to accommodate campus-scale, technology-oriented uses that combine office, technical,
<br />research, light industrial, and support functions in a planned setting. Data Centers fit that
<br />purpose. They are technology-based campus uses with limited general-public access,
<br />substantial investment in specialized information-technology infrastructure, and operating
<br />characteristics more closely aligned with computer networking, internet/web services,
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