West Richland's council made data centers a permitted use in February 2025¹. The Planning Commission hearing ran five minutes and the council hearing one minute, with no public comment at either^1,2. Bloom moved and Smart seconded, all seven council members were present, and the posted copy carries Mayor Brent Gerry's signature line^1,3.

On April 21, 2026 the council unanimously approved an agreement under which TC Northwest Development, which a 2017 Port of Seattle release describes as wholly owned by Trammell Crow, pays city staff costs^4,5,6. On May 5 it adopted ranch zoning that permits data centers in a new Mixed Use Light Industrial zone, with a 200-foot buffer where they abut residential or mixed use zoning^7,8.

In July 2026 one ranch parcel sold from Frank Tiegs LLC to TC West Richland 1 LLC for $82,728,295 and then to WKC31 Development LLC for $263,725,350, by the assessor's record⁹. No data center application had been filed as of the records checked^10,11,12. Who signed "For" the mayor on Resolution 16-26, and who sat on the 2025 council subcommittee, are not in any posted record⁵.

• The council adopted Ordinance 03-25 on February 18, 2025 on Bloom's motion and Smart's second, with all seven members present, after a hearing with no public comment¹.

• Community and Economic Development (CED) Director Eric Mendenhall prepared the April 21 and May 5, 2026 ranch staff reports, and the Community Development Department issued the 2025 environmental finding^3,13,14. City code makes the community development director responsible for administering the land division regulations¹⁵.

• On April 21, 2026 the council approved, on consent and unanimously, an agreement under which TC Northwest Development, a company a 2017 Port of Seattle release describes as wholly owned by Trammell Crow, agreed to pay for city staff time on its feasibility work^4,6,13.

• All seven council members voted for Ordinances 06-26, 07-26 and 08-26 on May 5, 2026⁷. The posted copy of Ordinance 07-26 says it was approved by the mayor on May 5, 2026 over Brink's signature line; the ordinance requires a 200-foot buffer where data centers abut residential or mixed use zoning or uses and an independent noise and air quality study before approval of the development^7,8.

• Roscoe Slade, the city's public works director, is named on the city's signature lines of the BENT-25-01 water right change application^16,17. The Benton County Water Conservancy Board approved the BENT-25 changes on January 13, 2026, and Ecology modified and approved BENT-25-01 on March 30, 2026^17,18.

• The Benton Public Utility District's service area excludes the City of West Richland, and Benton Rural Electric Association is the electricity provider for West Richland^19,20. The Bonneville Power Administration's queue lists request L0621, for a "West Richland Data Center Campus," at 912 megawatts with Benton Rural Electric Association as requestor²¹.

• A Fire District 4 board packet lists Fred Brink as a commissioner²².

• No data center application had been filed with the city as of the records checked^10,11,12. The only public statement from Trammell Crow on West Richland found for this brief was in print by November 15, 2025²³.

This brief follows the paper trail behind the zoning and utility decisions that opened part of West Richland's Lewis and Clark Ranch to data centers. It names who signed, moved, seconded and voted at each step, and which city department's name is on each document. It also lists what is still unknown and the records requests that would answer it.

No data center application had been filed with the city as of the records checked. Resolution 16-26 says the developer "has not submitted any permit applications," and staff said the same at council meetings in January and April 2026^5,10,11.

West Richland has a mayor-council form of government organized under Chapter 35A.12 of the Revised Code of Washington²⁴. The mayor is the chief executive in charge of all departments and employees, and appoints citizens to the Planning Commission²⁴.

Fred Brink beat May Hays 3,412 to 1,344 in the November 2025 election, certified November 25, 2025²⁵. According to the meeting video's auto-captions, he asked former mayor Brent Gerry to administer the oath of office at the start of the council's January 6, 2026 meeting^10,26. Gerry was mayor through 2025, and his name is on the mayor's signature line of Ordinance 03-25 and Resolution 38-25^1,3,27,28.

The council appointed Dan Richey to the vacant Position 6 seat on February 24, 2026 by a 5-1 roll call²⁹. Bloom, Cole, Fetto, Smart and Stoker voted yes and Moran voted no, with Stoker moving and Smart seconding²⁹. Brink gave him the oath on March 3, 2026³⁰.

The land is the Lewis and Clark Ranch. Frank Tiegs LLC, a limited liability company (LLC), applied to the city for the ranch's plan and zoning changes and is listed as owner of study-area parcels of 630.00, 457.64 and 571.50 acres in the final environmental impact statement³¹.

On January 5, 2023 the company paid the city $6.62 million for 1,000 water and sewer units³². The council approved the prepayment agreement under Resolution 07-23 on January 17, 2023, on Smart's motion and Fetto's second^13,33.

In February 2025 the council adopted Ordinance 03-25, which made data centers a permitted use in the Urban Transition and Light Industrial zones¹. The final environmental impact statement says the majority of the ranch inside the city is designated Urban Transition³¹.

On May 5, 2026 the council adopted the ranch subarea plan and its zoning⁷. Ordinance 07-26 repealed the Urban Transition district and says the new Mixed Use Light Industrial (MU-LI) zone allows data centers⁸. Ordinance 08-26 designates the Phase 1 area as a planned action area, and a legal description in the packet puts that area at 769.92 acres^8,14.

The assessor's record for one of the parcels lists a July 10, 2026 deed from Frank Tiegs LLC to TC West Richland 1 LLC for $82,728,295, and a July 16, 2026 deed from that company to WKC31 Development LLC for $263,725,350⁹. On September 1, 2026, Community Development Director Eric Mendenhall told the council that property in the Lewis and Clark Ranch area had been sold to Trammell Crow¹².

The table below lists each decision in the chain, who put a name or a vote on it, and which department's review appears in the public record. A blank review column means no department review was found in the packets, minutes or registers searched.

The 2025 code change, step by step

The city's Community Development Department issued the SEPA threshold determination of DNS on January 29, 2025³. Ecology's register lists Eric Mendenhall as the contact for the file and shows comments due February 13, 2025³⁶. The commission hearing opened at 6:09 p.m. that evening². Ecology's register lists no comment letters or appeal³⁶.

The council minutes summarize the staff report as saying the city "has received an application by Frank Tiegs, LLC" to change the Land Use Matrix¹. No record found shows which city body or official took that application up and decided to start the text amendment. A records request could ask.

The staff report and the ordinance recital say a council subcommittee voted unanimously on February 4, 2025 to recommend "do pass"^3,37. The staff report calls it the "Council Community and Economic Development Subcommittee," and the ordinance recital calls it the "Planning and Economic Development Subcommittee"^3,37.

The city's Agenda Center search results list only a City Council regular meeting under February 4, 2025³⁸. They show no notice, agenda, roster or minutes for that subcommittee meeting. No record found names its 2025 members³⁸. Smart's campaign site says he "serves on the West Richland Community Development subcommittee"⁵². It does not say who sat on the subcommittee on February 4, 2025⁵².

A council subcommittee also recommended Ordinance 01-25 on January 7, 2025 and power generation as a conditional use on April 29, 2025^35,53.

The staff report said data centers "bring daytime jobs, are a significant source of utility and sales tax revenue." It also said "details will not be provided at this time do to request from applicant"³⁷.

The commission hearing on February 13, 2025 ran from 6:09 to 6:14 p.m.². The minutes record no public testimony. Brady moved and Utecht seconded, and the motion "passed unanimously." The minutes record a motion to excuse Peterson and Retter, which leaves five of the seven commissioners present².

The council hearing on February 18, 2025 ran from 6:14 to 6:15 p.m. with no comments¹. Gerry opened and closed it. Bloom moved, Smart seconded, and the council approved the ordinance unanimously by voice vote with all seven members present^1,39.

On the video of that meeting, according to the auto-captions, Mendenhall said Tiegs had "something in the works" that might come the city's way if the change was approved (12:47), and cited "about two employees per acre" (13:11)³⁹.

Both agendas went online ahead of the meetings. An earlier version of the commission packet was posted February 6, the current listing shows February 13, and the council's materials were posted February 14^54,55. Each meeting held a public hearing on the code change^1,2.

The Municipal Research and Services Center (MRSC) says state statutes "do not specify how legislative public hearings should be conducted," while the rules for quasi-judicial hearings are "much stricter"⁵⁶. Courts, it says, "simply assess whether the legislative body had the authority to act in the way that it did, and whether such action was arbitrary and capricious"⁵⁶.

This research found no Washington case voiding a legislative hearing because it was short or drew no testimony.

The draft ordinance in the commission packet already recited that the council voted to approve the change on February 18, 2025, and an earlier version of the packet was posted February 6^37,54. The posted copy of Ordinance 03-25 carries Gerry's signature line, a signature over Haug's printed name as clerk, and a mark the OCR cannot read over Foltz's printed name as city attorney³.

The ranch plan and the 2026 zoning

The Planning Commission recommended the preferred alternative on July 31, 2025, with Sloughter moving and Utecht seconding⁴⁰. Keith Tiegs "spoke on behalf of the applicant Frank Tiegs LLC"⁴⁰. The council adopted it August 12, 2025, unanimously, with Fetto moving, Moran seconding and Stoker excused⁴¹.

The March 10, 2026 final draft of the subarea plan lists data centers among the uses allowed in MU-LI, on plan page 18⁵⁷.

The ranch hearing notice went up March 30, 2026, ten days before the April 9 commission hearing⁵⁸. The notice does not mention data centers⁵⁸. On April 9 the commission voted unanimously on Peterson's motion and Aldrich's second, and Retter asked to be excused⁴⁵.

The April 21 and May 5, 2026 staff reports, prepared by Mendenhall and reviewed by Brink, carry the line "MULI Regulations (Data Centers): Allowed in MULI zone near Phase 1."^13,14 It sits under the heading "Public Comment at Planning Commission Hearing," in a summary of comments made there^13,14.

On May 5, 2026, the council voted unanimously for Ordinances 06-26, 07-26 and 08-26 with seven members present⁷. Brink presided, and the posted copy of Ordinance 07-26 says it was approved by the mayor on May 5, 2026 over his signature line^7,8. The approved-as-to-form line on 07-26 carries a mark that includes "31981" above Jessica Foltz's printed name, and the Washington State Bar Association (WSBA) lists license number 31981 for Michael J Rio^8,47.

Ordinance 07-26 requires a buffer of at least 200 feet where a data center site abuts residential or mixed use zoning or uses⁸. It separately requires an independent noise and air quality study before approval of the development⁸.

Trammell Crow's agreement with the city, April 2026

Resolution 16-26 approved a reimbursement agreement with TC Northwest Development, Inc., a Delaware corporation⁵. A 2017 Port of Seattle release says Trammell Crow Company created TC Northwest Development as a wholly owned company⁶.

The agreement is dated April 15, 2026, takes effect April 1 and runs three years^5,13. It estimates costs "not to exceed $150,000" and requires the company to pay for any added work it requests⁵. Mark Netherland is named as signer for the company as Senior Vice President⁵.

State law lets cities collect "reasonable fees from an applicant" to cover the cost of "processing applications, inspecting and reviewing plans"⁵⁹. Resolution 16-26 recites that the developer "has not submitted any permit applications and therefore, there is no mechanism to charge for the Work Requested"⁵. The council approved a similar reimbursement agreement with Frank Tiegs LLC for the ranch EIS on consent January 21, 2025³⁴.

Mendenhall's staff report, reviewed by Brink, said the developer "is conducting a feasibility analysis for a large industrial complex" and that staff expected "an estimated 30 hours per week in technical assistance"¹³.

The mayor's line on the signed Resolution 16-26 reads "For" above Fred Brink's printed name, which suggests someone signed on Brink's behalf⁵. No record states who signed. The agreement's own signature page has a "Fred Brink, Mayor" line⁵.

The approved-as-to-form lines on Resolutions 16-26 and 18-26 carry handwritten marks over Foltz's printed name that the OCR reads as "Mutod 1 fs 31B816" and "Medan f to 31721k7"^5,32. The April 21 minutes list Michael Rio as city attorney that night⁴. No record states whose marks they are.

Ordinance 05-26 booked the $150,000¹³. Finance Director Erin Gwinn prepared the report and Brink reviewed it¹³. The packet's budget exhibit labels the lines "TC Northwest Development"¹³. The signed copy labels them "Trammel Crow"⁴⁶.

Resolution 18-26 lets Tiegs allocate its last 286 prepaid units to four areas, among them "Parcels 1 through 6" of a preliminary record of survey for an exempt parcel segregation³². The survey sheets in Exhibit C carry the title-block line "CLIENT: TRAMMELL CROW COMPANY"³². The 286 units equal about 132,132 gallons a day of water and 44,500 gallons a day of sewer capacity³².

City departments, one by one

Community and Economic Development: Mendenhall is named as the SEPA Responsible Official in a city SEPA notice on the ranch¹⁶. City records give his title both as Community Development Director and as Community and Economic Development Director^60,61.

Public Works: Roscoe Slade is the printed name on the city's three signature lines of the BENT-25-01 water change application, as water right holder and as owner of the existing and proposed places of use¹⁶. Ecology's March 30, 2026 letter addresses him as Public Works Director¹⁷. The signature page carries dates of April 7, 2025 and August 6, 2025¹⁶. He is listed as preparer of the staff reports for Resolutions 51-25, 18-26 and 20-26^13,27.

Finance: Director Erin Gwinn is listed as preparer of the staff report for the budget amendment that the agenda lists as Ordinance 05-26¹³. City Clerk: Stephanie Haug attested Ordinance 03-25³. The staff directory lists her as City Clerk⁶⁰.

City Attorney: Jessica Foltz is City Attorney for West Richland, according to her firm's website⁶². The firm, Rio Foltz PLLC, was started by Foltz and Michael Rio in 2023⁶².

Building and fire: Todd Blevins is listed as Building Official⁶⁰. The Fire District 4 board's minutes of April 2, 2026 record its chief meeting with "City Fire Marshal Todd Blevins"⁶³[c2019b]. Under city code, the Building Official issues a certificate of occupancy only after all city departments approve⁶⁴.

No Public Works, engineering, building, fire, police or finance comment on TXT-0001-2025 appears among the documents the SEPA register lists for it [c2021a]³⁶. Records requests R10 and R11, below, would show whether any exists³⁶.

Bodies outside City Hall

The Benton County commissioner agendas that were searched show no action naming the ranch, Tiegs, the buyers or a data center. Only agendas were searched, not packets.

Benton REA, not Benton Public Utility District (PUD), serves the site^19,65.

The Benton County Water Conservancy Board's records of decision cover change applications BENT-25-01 through BENT-25-12¹⁸. The one for BENT-25-01 says it was made at an open public meeting held on January 13, 2026¹⁸. The file holds 12 records of decision with the Approval box marked¹⁸. The BENT-25-01 record grants conditional approval and sends the decision to Ecology for final review¹⁸.

The scanned signature lines on those records could not be read reliably, so who signed each decision is not confirmed here.

Ecology's report of examination for water right S4-33044(B2) [c2031a] lists a quantity authorized for withdrawal or diversion of 12.758 cubic feet per second (cfs) and 3,539.85 acre-feet a year⁴⁹, for municipal water supply [c2031b].

It is signed at Union Gap, Washington on August 25, 2026 by Scott Turner, Operations Section Manager, Office of Columbia River⁴⁹. The report says the authorization will provide water for phase one of the Lewis and Clark expansion⁴⁹. It does not mention data centers.

At the Port of Benton's October 15, 2025 commission meeting, the minutes record that in the discussion of Atlas Agro's power requirements it was stated the project is viewed by many as providing infrastructure to "multiple large-scale users, such as data centers"⁶⁶. The minutes do not mention Trammell Crow or Tiegs.

What the mayor and council members have said on the record

NDA means nondisclosure agreement. Quotes from meetings come from the city's YouTube recordings, read in YouTube's transcript panel and checked against the minutes. The captions are machine-made, so names follow the minutes. Filler words, stutters and false starts are dropped and caption misspellings such as "moratorum" are fixed; any other cut is marked with an ellipsis.

Stoker made no recorded remark on data centers in his council comments on August 4, August 18, September 1 or September 15, 2026^50,67,68,69. He spoke about council rules⁶⁷, a fireworks ordinance change⁶⁸, Constitution Month⁶⁹ and budget workshops⁵⁰.

Sign-offs still to come

A data center is allowed in the Light Industrial (LI) zone and the Mixed Use Light Industrial (MU-LI) zone. Ordinance 03-25 allowed data centers as a permitted use in the Urban Transition and Light Industrial districts³. At the May 5, 2026 meeting a council member said data centers would now be either in light industrial or mixed use light industrial, and the reply was "That is a correct statement"⁷⁰.

The Lewis and Clark Ranch subarea regulations were adopted as Ordinance 07-26⁸, and they say the MU-LI zone allows data centers⁸.

The draft code text in the Planning Commission's October 1, 2026 packet lists Type I permits as including permits for permitted uses not requiring site plan review by the planning commission or city council⁷².

For Type I, its permit table shows the director as decision-maker⁷², no notice of application⁷², no public notice except for unit lot subdivisions⁷², and a judicial appeal under chapter 36.70C of the Revised Code of Washington (RCW), the Land Use Petition Act (LUPA)⁷².

Whether a given data center permit would be Type I turns on whether it needs site plan review, and no posted record settles that.

Ordinance 07-26's MU-LI standards require data centers to have at least a 200 ft landscaped buffer where they abut residential and mixed use zoning or uses⁸, and an independent noise and air quality study before approval⁸.

TXT-0006-2026 would give a hearing examiner conditional use permits, preliminary plats other than short plats and plats tied to planned unit developments, major revisions of those plats, and major variances⁷³. Ecology's SEPA register lists a DNS for it dated July 16, 2026⁷³. The Planning Commission's September 10, 2026 agenda lists hearings on TXT-0005-2026 and TXT-0008-2026⁷⁴, and the council's October 6, 2026 agenda lists no TXT-0006-2026 item among its regular items⁵⁰.

The October 6, 2026 consent agenda carries Ordinance 28-26, which establishes an office of hearing examiner to hear code enforcement appeals⁵⁰. It also carries Ordinance 27-26, which adds section 17.54.460, Violation; Penalties, to the West Richland Municipal Code (WRMC)⁵⁰. The Planning Commission's October 1, 2026 special meeting agenda listed the same code enforcement text amendment as an action item, with the section number printed as 14.54.460⁷².

Slade is listed as preparer of both council staff reports and Brink as reviewer⁵⁰. The regular agenda has no data center item⁵⁰.

The council also called a 5:15 p.m. executive session for October 6 to discuss with legal counsel "the legal risks of a proposed action or current practice"⁷⁵. The agenda does not name the subject, and nothing in the record ties it to data centers.

Brink's nominee for Planning Commission Position 5, Tyler Aspinwall, is on the same consent agenda⁵⁰. Commissioner Colton Brady is on the commission's July 31, 2025 roster⁴⁰ and answered the roll at the January 13, 2026 joint meeting⁷⁶. He is not listed in the April 9, 2026 minutes⁴⁵ or the May 14, 2026 minutes⁷⁷, and the May 14 minutes record staff mentioning an open vacancy⁷⁷. No record gives the reason.

A valid and fully complete building permit application is considered under the zoning and land use rules in effect on the date of application⁷⁸. In Potala Village v. Kirkland, the court wrote that failing to file a completed building permit application before the city's moratorium barred vesting of rights to the earlier zoning rules for the entire project⁷⁹. It noted that the validity of the moratorium was not at issue⁷⁹.

Frank Tiegs LLC was the applicant named in Ecology's SEPA register record for the code change that allowed data centers³⁶. The summary in the Planning Commission packet said data centers "bring daytime jobs, are a significant source of utility and sales tax revenue"³⁷, and that details "will not be provided at this time do to request from applicant"³⁷.

Speaker names for quotes taken from meeting captions are matched to the minutes; the captions misspell several of them.

At the February 18, 2025 council hearing, Mendenhall said Tiegs had "something in the works" that "might come our way" if the change was approved³⁹. He cited "about two employees per acre" for data centers³⁹.

A 2026 legislative priorities document in the October 7, 2025 council packet included the line "The City of West Richland supports data centers and colocations with SMR generation that include industrial symbiosis"⁴³. SMR means small modular reactor. The same line is in the priorities attached to Resolution 38-25²⁸. The council passed that resolution October 21, 2025²⁸, on the consent agenda⁴².

On January 6, 2026 the staff speaker the captions render as "Mr. Menhal" told residents "the city has not received any applications yet"¹⁰, adding "we don't do that until we actually have an application in"¹⁰.

On January 13, 2026, a participant asked whether the Tri-City Development Council (TRIDEC) had seen the light industrial area⁷⁶. Mendenhall said "Last year I had a meeting with uh Carl and David" (the captions spell the second name "Refog")⁷⁶. He said they had no recommendations on changing anything⁷⁶. He said Carl raised the idea of a heating district if a large industry with steam as an output went in⁷⁶, which Mendenhall called "industrial symbiosis stuff"⁷⁶.

Matching the names to TRIDEC's Karl Dye and David Reeploeg is an inference. The Port of Benton's approved minutes for its October 15, 2025 meeting list Karl Dye of TRIDEC and David Reeploeg of Hanford Communities/TRIDEC among those present⁶⁶.

On April 21, 2026 Mendenhall told the council: "To be clear, the city has not received any application for a data center project"¹¹. He added, "There is interest in the [Lewis] and Clark Ranch"¹¹.

At the May 5, 2026 adoption, after the mayor recognized Mayor Pro Tem Bloom, the captions record the exchange ending with "there currently isn't any light industrial in phase one for data centers"^7,70; the caption speaker markers do not make clear whether Bloom or a staff member said that line. Mayor Brink closed the meeting by saying "There is 100% transparency"⁷⁰.

On September 15, 2026 Mendenhall said "fear-mongering" spread online "is just that," and "we are going to have a complete public and open process with this project should one come in"^50,71.

At the same meeting he said a moratorium's environmental analysis, staff time and consultants "would be a taxpayer burden, not a developer burden"⁷¹. He left the choice to the council⁷¹.

Benton REA says that under its "board-approved policy," a requesting data center "must pay for the infrastructure required specifically to serve its load." The page gives no adoption date or vote⁸⁰.

Trammell Crow said it "is studying the feasibility to develop a portion of the Lewis and Clark land," in a statement to the Tri-Cities Area Journal of Business dated December 2025 in the copy read²⁰. A Tri-City Herald story by Wendy Culverwell, dated November 15, 2025 in the republished copy read for this brief, carried the same statement²³.

No later public statement from Trammell Crow or its companies was found in council minutes, news coverage or filings checked for this brief. The September 2026 Herald story on the sale described the buyer as "a company identified as the data center arm of real estate giant Trammell Crow"⁸¹. The part visible without a subscription does not say who made that identification.

Supporters, conditional backers and the power cooperative in public comment

Josh Lozano, who said he works for Benton REA as its director of energy policy, spoke at the August 18, 2026 council meeting^68,82. He said "existing members will not be responsible for subsidizing data centers or any large load for that matter"⁶⁸. Citing an E3 study⁶⁸, he said "properly structured data center loads can actually generate revenue" that meets and exceeds the utility's cost of service⁶⁸.

He closed with the cooperative's approach: "Protect existing members, preserve reliability, and require large loads to pay for themselves"⁶⁸.

On September 15, Deputy General Manager Troy Berglund said the cooperative "cannot discriminate when a new potential load or business or home or anything comes to inquire about electric service"^50,71. He said the board's policy puts "all costs, all risks associated with that project" on the data center⁷¹.

Derek Warcheck, a business agent for United Association (UA) Local 598, a plumbers and steamfitters union local, told the council the same night: "I am for this project as I currently already have 350 members, 120 registered apprentices building, maintaining and retrofitting the data centers in Quincy, Umatilla, Hermiston and Boardman, Oregon"^50,71. He added that "people are going to hate what they don't understand"⁷¹.

Andrew Rice, a construction worker, said "I spent 10 years driving to Quincy to feed my kids"⁷¹. The minutes say he backed local construction work "that would reduce the need to commute to Quincy"⁵⁰.

Ken Polenski of Benton County said "This is not just a ramrodding type of project"⁷¹ and "I'm for the data center"⁷¹. He added, "I came from a community that started saying no to projects, and the community dried up"⁷¹. The minutes say he "opposed imposing a moratorium at this stage"⁵⁰.

Two other speakers set conditions or took no side, the minutes say. Randy Walli "supported growth if the City conducts due diligence, establishes safeguards"⁵⁰. Pablo of Benton City expressed neither support nor opposition and spoke for "requiring developers to pay for energy and infrastructure costs"⁵⁰.

In a blog post dated July 24, 2026 on its site, the Tri-City Regional Chamber of Commerce wrote that "For the Tri-Cities, data centers can be a good fit if growth is carefully managed"⁸³. It added that projects "should be supported because they benefit the community, not just because the industry is expanding"⁸³. The post does not name West Richland.

The earliest mention of data centers in Appendix U, the Final EIS comment-letter volume, is a July 9, 2025 email from Herb and Susan Johnson: "the proposed data centers in the western part of ranch will multiply traffic"⁸⁴.

Ken Humphreys wrote on July 30, 2025: "Who do you think will win that competition (e.g., an AI data center or a West Richland development)?"⁸⁴ AI means artificial intelligence. The Final Environmental Impact Statement (EIS) responses to both letters, 16a and 19d, do not use the words "data center"³¹.

The Final EIS text has no mention of "data center"³¹. The phrase appears once in Appendix T⁸⁵ and three times in Appendix U⁸⁴.

On April 21, 2026 Smart said he had "personal emails from five different residents concerning the potential for densification and in a data center"^4,11.

At the May 5, 2026 adoption, resident Jerry Boggs said: "It seems inevitable to me that [Trammell] Crow will reach some type of agreement with the Frank [Tiegs] LLC and that at some point you will be facing an application for a huge data center"^7,70.

City staff referred to the company by the name on the agreement. Gwinn named "TC Northwest Development" on April 21^4,11, and that night's packet printed a client line the OCR reads as "TRAMMELLCROWCOLIPANY" on a survey exhibit¹³. In the council minutes and captions read for this brief from October 7, 2025 to May 5, 2026, the only spoken mention of Trammell Crow found was from a resident⁷⁰; no city official was found saying the name.

Requests for a moratorium or conditional use review

On August 18, a resident the minutes name only as Anna asked the council to consider a data center moratorium⁸². The minutes say she wanted time "to research potential impacts and establish local policies before an application is submitted"⁸².

At the September 10 Planning Commission meeting, the minutes say Elizabeth Emmens asked that "large-load data centers be classified as conditional uses rather than permitted uses, allowing each project to receive individual review"⁷².

The September 15 council minutes list a Liz Emmons of West Richland recommending plan policies on cumulative water demand⁵⁰; whether that is the same person is not confirmed here. Emmens also recommended performance standards on water, power, wastewater, noise, emissions, lighting and other topics, including decommissioning and reporting⁷².

On September 15, Fetto counted "44 public comments about data centers"⁷¹. Smart counted 47, four of them on other subjects⁷¹.

Tony Carr told the council he was giving the clerk "a moratorium supporting evidence package"^50,71. He asked for "a narrowly defined pause on accepting qualifying large load data center applications" while the city completes its plan update and decides in public whether these facilities should require conditional use review and stronger standards⁷¹. The package does not appear in the council packets read for this brief.

Carrie McCammon (the minutes spell it McHammond) warned that filing a "technically complete application" can lock in the development rules then in effect^50,71. A moratorium adopted before vesting, she said, "would preserve the city's ability to finish that work. It would not decide the project's outcome"⁷¹.

Alyssa Huckaby said: "If the city plans for an industrial development at an unprecedented scale, it should adopt safeguards proportional to that scale before an application locks in today's rules"⁷¹. She added, "Many residents say they did not understand that the 2025 code amendment made data centers a permitted use in the light industrial and urban transition zones"⁷¹.

Huckaby asked for a moratorium ordinance and a public work plan covering "conditional use review, applicant-paid analysis, operational standards, decommissioning, and public reporting," the minutes say⁵⁰.

Christine Bays asked for "a narrowly tailored moratorium on the acceptance, processing, and vesting of applications for large load data centers"^50,71. Answering the worry that limits would reach every business, she said, "An ice cream shop should not be subject to the standards designed for major electrical demand, backup generation, cooling systems, noise, water use, or decommissioning"⁷¹.

A resident the minutes name only as Tyler asked for "enforceable cost allocation and financial security requirements for infrastructure, cancellation, decommissioning, and site restoration," the minutes say⁵⁰.

Two Change.org petitions oppose data centers. One started June 3, 2026 calls for an "immediate, official 1-year moratorium on the approval, permitting, and construction of data centers" in Richland and West Richland⁸⁶. The page retrieved October 5, 2026 shows the figure 3,709 where the signature count sits, without the label⁸⁶.

The other, started March 5, 2026, asks the council to "reverse its decision to allow data centers in urban transition and light industrial zones"⁸⁷. The same day the page showed 702 in the same place⁸⁷. Neither petition appears in the council and commission packets read for this brief, and no record found shows either was delivered to the city.

How neighbors handled data centers

Pasco's council voted 6-0 to adopt Ordinance 4850, a six-month moratorium on licenses and permits for new data centers, according to draft minutes of its July 20, 2026 meeting⁸⁸. Charles Grimm, Pasco's mayor, was listed as absent⁸⁸.

Richland's council approved Resolution 2025-146, an option agreement with Atlas Agro, Inc. for 275 acres, 6-0 on December 2, 2025, with Mayor Pro Tem Kent excused⁸⁹. On June 16, 2026 it adopted Resolution 2026-84 by 5-0⁹⁰. The resolution authorizes a reimbursable agreement with the Bonneville Power Administration (BPA) and a second BPA cost allocation agreement with Atlas Agro Data Center, LLC⁹⁰.

A search of Prosser's code for "data center" returned no results⁹¹. The cached copy of Benton City's zoning title has no match for the phrase either.

No tax abatement or incentive from the city, the Port of Benton, the Port of Kennewick or TRIDEC turned up in the sources read for this brief.

Power

Benton REA declined to release its cost-recovery agreement, a news story reported, and told the Tri-City Herald it is not subject to the Washington Public Records Act²³. The story quotes a statement attributed to Troy Berglund, the co-op's deputy general manager, that no decisions had been made²³.

Benton REA's bylaws say the association is to operate on a cooperative non-profit basis for the mutual benefit of its members⁹². They refer to Chapter 23B.13 of the Revised Code of Washington on dissenters' rights⁹². The bylaws do not say which statute gives members a route to the co-op's records.

Benton REA's July 2026 newsletter lists Scott Fisher as President, Mike Freepons as Vice President and Bill Shibley as Secretary/Treasurer⁹³.

In an email printed in the Final EIS appendices, Community Development Director Eric Mendenhall asked Troy Berglund of Benton REA to help answer a draft EIS comment about electricity^60,85. He wrote that a reply "Coming from BREA would be solid and less likely to raise eyebrows to the response"⁸⁵. The email is dated August 18, 2025⁸⁵.

Berglund replied on August 20, 2025, in general terms about the partnership and growing demand⁸⁵. As printed, his reply does not name request L0621, which BPA's queue lists under the project name "West Richland Data Center Campus," with Benton REA as requestor and a request date of September 6, 2024²¹. The Final EIS response says the city's request for written confirmation and the email were provided in Appendix T³¹.

The Final EIS added "a check in with Benton REA at every 2,000 ERUs allocated for development in Phase 1, to confirm power supply will be available"³¹. ERU means equivalent residential unit.

Water

Ecology's report of examination approving the city's water right application S4-33044(B2)⁴⁹ says notice was published in the Tri-City Herald during the weeks of May 12 and 19, 2024⁴⁹. It says no protests were received⁴⁹. The report describes the application as 3,000 acre-feet a year at 12 cubic feet per second⁴⁹.

The change applications before the Benton County Water Conservancy Board are numbered BENT-25-01 through BENT-25-12¹⁸. Ecology's March 30, 2026 modified decision on the first of them lists Well 12 and a Well 13 whose coordinates are still marked "TBD"¹⁷. The report of examination says no additional water is requested or allocated under the changes¹⁸. It also says Well 13 is required for the initial phases of the Lewis & Clark Ranch development¹⁸.

No BENT-25 file read mentions a data center, Trammell Crow or the buyer companies¹⁸.

The record of decision's signature block names Darryll Olsen as chairman of the Benton County Water Conservancy Board¹⁸. The county commissioners' May 24, 2022 consent agenda lists his reappointment⁹⁴. A resolution dated June 11, 2024 re-appointed Scott Revell for a term expiring May 31, 2030⁹⁵. The revised June 2, 2020 agenda lists the reappointment of Matt Berg⁹⁶.

The state statute on conservancy boards says a board is subject to the Public Records Act⁹⁷. It also has a section titled "Application of open public meetings act"⁹⁷. The State Auditor's report says it noted matters about meeting minutes documenting Open Public Meetings Act compliance, raised in a letter dated November 26, 2025⁹⁸.

The December 16, 2025 council packet carries RES. 51-25, a third amendment to the wholesale water agreement with Richland²⁷. Public Works Director Roscoe Slade's staff report says West Richland expects a new surface water right "to meet potable water demands for an estimated additional 7,000+ residential dwelling, commercial, and industrial units in the Lewis and Clark Ranch area"²⁷.

Fire District 4

The fire district's minutes record a Commissioner Brink moving to approve the consent agenda on May 7, 2026²². That day he also gave the city liaison report, on the week's City Council meeting²². On April 2 the liaison report came from Councilmember Fetto⁶³.

The city's outside-agency list for 2026 puts Fred Brink and then David Fetto on its Fire District 4 line²⁶. Council minutes list Fred Brink as mayor¹². No filing in the sources read lists both offices for one person, so this brief does not confirm that the commissioner and the mayor are the same Brink.

Attorney General Opinion AGO 2016 No. 7 quotes a June 27, 2001 informal letter that found the offices of city council member and fire district commissioner incompatible⁹⁹. The letter itself was not read. The same opinion cites AGO 1978 No. 12, which found mayor and port commissioner incompatible⁹⁹.

No opinion found in this research addresses a mayor holding a fire commissioner seat. No source found says those two offices are incompatible, and no challenge to such an arrangement involving Brink was found.

The fire chief's report in the March 19, 2026 minutes says "the City has indicated that the District will be responsible for purchasing a one-acre parcel" for a new station¹⁰⁰. In the April 2 minutes, the chief's report reviews the district's interlocal agreement with the city, which the minutes call "significantly outdated"⁶³.

The district's minutes do mention the ranch. The June 5, 2025 minutes record the chief meeting Mendenhall about the Lewis and Clark Ranch expansion¹⁰¹. The June 19, 2025 minutes record that he "Participated in the EIS kickoff for the Lewis and Clark Ranch expansion"¹⁰². The district minutes read here do not mention Tiegs, Trammell Crow or data centers.

Overlapping boards and conflicts checks

Benton REA's newsletter lists Ted Wallace as Trustee, District 7⁹³. A council packet's suggested motion was to confirm Mayor Gerry's appointment of George "Ted" Wallace to Salary Commission Position #5¹⁰³. The council minutes of December 5, 2023 list that confirmation on the consent agenda, with Councilmember Moran moving and Councilmember Fetto seconding¹⁰⁴. No record read confirms that the trustee and the appointee are the same person.

On September 15, 2026 the council unanimously approved a consent agenda that included a motion confirming board and commission appointments⁵⁰. The packet's suggested motion named four Salary Commission appointees: Harry Mays, T. Joshua Lazano, Michael Van Beek and Billie Paden-Lilly⁵¹. Lozano's application letter says he is Director of Energy Policy for Benton Rural Electric Association⁵¹.

Fire District 4's minutes list Commissioner Van Beek among the board members present⁶³. They also list a Finance Manager Paden-Lilly⁶³.

The city's 2026 outside delegate list has no line for Benton REA, Benton PUD or the Port of Benton²⁶. Fred Brink is on its TRIDEC Board of Directors line²⁶.

Moran signed a Public Disclosure Commission (PDC) statement of understanding in case 193546, saying she did not timely file the F-1 report due April 15, 2026 for calendar year 2025¹⁰⁵. The statement says she was sending $200 for the late-filed report, and it carries a signature date of 08/18/2026¹⁰⁵.

The Final EIS says it used technical reports from the applicant's consultant Apex (formerly PBS)³¹. Apex's own notice says PBS joined Apex in 2024¹⁰⁶. No tie between Apex and any named official was found.

No recusal or conflict disclosure appears in the minutes read for the council's votes on Ordinance 03-25 and Ordinance 07-26^1,7.

Council rules and notice

Resolution 46-26 amends the council's rules of procedure, and the revised rules take effect September 1, 2026¹⁰⁷. Rule 11, Committees, says committee meetings "shall not be subject to the Open Meetings Act" unless the council delegates duties such as taking public testimony, conducting hearings or acting on its behalf¹⁰⁷. It also has the mayor designate staff who prepare the agenda, give notice, keep minutes and record attendance¹⁰⁷.

The RES. 18-21 rules in the May 18, 2021 packet¹⁰⁸ mention committees only in the sanctions clause, with no committee section.

That tracks state law as the Municipal Research and Services Center (MRSC) describes it.

A council committee is covered by the Open Public Meetings Act (OPMA) when it acts on behalf of the council, conducts hearings, or takes testimony or public comment¹⁰⁹. MRSC says "when a committee is not doing any of those things, it is not subject to the OPMA"¹⁰⁹. It adds that opening such meetings anyway is "usually good public policy"¹⁰⁹.

No record found shows what the Community Development Subcommittee did beyond its recommendation¹.

No hearing notice for TXT-0001-2025 appears in the city's News Flash archive as captured in mid-February 2025^36,110. The same archive does list other text amendment notices¹¹⁰. Absence from one archive is not proof.

For Type III, IV and VI project permit applications, the city code section on notice requires mailing to owners within 600 feet, posting on or near the property, and posting on the city website or at the official posting places at least 21 days before a hearing¹¹¹.

The state statute on hearings for a city's long-range plan requires newspaper publication at least ten days before a hearing on that plan or a part of it¹¹². Whether either rule applies to a zoning text amendment is not settled here.

Appeals and court records

No appeal of the water right approval, the BENT-25 changes or the ordinances turned up in the sources read^18,49. Cases naming the city or the companies need a search by the Benton County Clerk.

The 2017 hearings board case

The state hearings office site lists a Growth Management Hearings Board final decision and order dated 2018-03-26¹¹³. The cached page text carries only the document details, not the order itself.

This site published an earlier brief on the February 2025 hearing in September 2026¹¹⁴. A separate corrections note covers it¹¹⁴. The records checked for this brief change these points:

• The 2025 mayor's race was 3,412 to 1,344²⁵, not 2,500 to 930¹¹⁴.

• The April 9, 2026 commission vote was unanimous with four present (O'Neill, Peterson, Utecht, Aldrich)⁴⁵, not 3-0¹¹⁴. A line in the minutes "excusing" Utecht appears to be a slip; he spoke at the hearing⁴⁵.

• Seven people spoke at the April 21, 2026 hearing⁴, not eight¹¹⁴.

• The minutes record the August 12, 2025 vote as unanimous, on Fetto's motion and Moran's second, with Stoker excused and six members present⁴¹. The earlier brief had reported it only as unanimous¹¹⁴.

• Staff did name data centers in 2026: in the draft subarea plan in the April 21 packet¹³, in the staff report as the minutes summarize it⁴, and aloud on April 21¹¹. The earlier brief said the words did not appear in the staff presentation¹¹⁴.

• The April 21 consent agenda also passed Resolution 16-26, the staff-time agreement with TC Northwest Development^4,5. The earlier brief described a reimbursement agreement with Frank Tiegs LLC¹¹⁴.

• Trammell Crow's name was in city records from April 2026, on the signed Ordinance 05-26 and a survey exhibit in the April 21 packet^13,46.

• The earlier brief said Trammell Crow had filed no pre-application¹¹⁴. None was found for this brief either. The earlier brief did miss that an entity named TC Northwest Development, Inc. signed an agreement to pay for city staff, consultant and attorney time⁵, effective April 1, 2026¹³, and the resolution approving it recites that no permit applications had been submitted⁵. No record shows an invoice paid.

• Trammell Crow's statement appears in a Herald story dated November 15, 2025 in the copy read²³; the earlier brief dated it to December¹¹⁴.

• The Port of Benton's approved minutes do not mention the remark. The earlier brief said Mayor Gerry declined further questions and the city issued a statement¹¹⁴; that rests on one news story²³.

• The sale was seven parcels totaling a little more than 995 acres⁸¹, not five parcels and about 1,061 acres¹¹⁴. The Trammell Crow survey sheet in the April 21 packet covers land in Sections 27, 28, 29, 33 and 34¹³.

• The one sold parcel whose Assessor record was available, 134071000000001⁹, is not on the Phase 1 parcel list in Ordinance 08-26, which includes only part of 134071000000000¹⁴. The records checked do not show whether that Phase 1 corner was sold¹⁴.

• Benton REA's website now cites a "board-approved policy" with no date⁸⁰. The earlier brief said the site carried no large-load policy on the project¹¹⁴.

• Ecology approved S4-33044(B2) on August 25, 2026; it is not pending⁴⁹. Its priority date is November 28, 2011⁴⁹. October 2022 is when the Quad Cities' public works directors signed to split off West Richland's share, per the Final EIS³¹. The earlier brief had called it filed that month¹¹⁴.

• TXT-0006-2026 does exist, as SEPA record 202603014⁷³. The earlier brief said no record of it existed¹¹⁴.

• Agenda notice for the February 2025 hearings is confirmed: the council agenda was posted February 14, 2025⁵⁵, and the Planning Commission materials February 13, 2025⁵⁵. No published hearing notice was found. The April 2026 ranch hearings did have a website notice⁵⁸, which ran from March 30 to April 9, 2026⁵⁸.

• "Data center" appears zero times in the Final EIS text, once in Appendix T and three times in Appendix U^31,84,85. The earlier brief had said the phrase appeared only in an appendix index entry¹¹⁴.

• Richland's December 2, 2025 vote on the Atlas Agro option agreement was 6-0, with Mayor Pro Tem Kent excused⁸⁹. The earlier brief said the project advanced with all seven council members' support¹¹⁴.

Other places where records do not line up:

• City code lists no route for a private party to start a text amendment¹¹⁵, yet the SEPA register record and the Planning Commission summary name Frank Tiegs LLC as the applicant^36,37.

• The Final EIS numbers the Humphreys letter 19³¹; Appendix U numbers it 20⁸⁴.

• Ordinance 05-26's Exhibit B reads "TC Northwest Development" in the packet¹³ and "Trammel Crow" in the signed copy⁴⁶.

• A 2024 Puget Sound Energy release quotes a Mike Nelson as Trammel Crow's Seattle office market leader¹¹⁶. No cached record connects him to the buyer entities in West Richland.

Each item says what is unknown, what was searched, and the route to an answer. R and O numbers refer to the records requests listed after this section.

• Who signed "For" the mayor on Resolution 16-26^5,14. The cached Tiegs prepayment resolution and the September 1, 2026 minutes show only the typed line for the mayor, so the text does not say whether someone signed for him there^12,32. Searched: the resolutions, minutes and videos; route: ask City Clerk Stephanie Haug and file R5^14,60.

• Who labeled the revenue and expense lines in the Ordinance 05-26 budget exhibit "Trammel Crow" instead of the developer's legal name, and when^14,46. Searched: packet, signed copy, minutes; route: R21, or ask Finance Director Gwinn^46,60.

• What staff did for TC Northwest Development under Resolution 16-26, with invoices and hours¹⁴. Searched: packets and budget ordinances; route: R5¹⁴.

• Who sat on the subcommittee that recommended passage of the data center ordinance, and whether that meeting had notice or notes¹. Searched: the Agenda Center and the meeting video; route: R3¹.

• Whose voice is on the Port of Benton audio⁶⁶. Searched: machine transcript, approved minutes. Route: a person listens to the recording.

• What the purchase contracts behind the July 2026 recorded instruments say, and whether the city held copies¹¹⁴. The earlier brief lists a Tiegs agreement with TC West Richland 1 LLC indexed as 2026-018770¹¹⁴; the recorder's index itself was not cached for this brief. Route: R7⁶⁰.

• Whether Public Works, City Engineer Drew Woodruff, the Building Official, police or finance reviewed the code change or the ranch plan⁶⁰. Searched: packets, SEPA register, Fire District 4 minutes; route: R10, R11, O4^60,100.

• Whether Tiegs assigned any of the 286 prepaid units to the sold parcels³². Searched: recorded instruments and packets; route: R9³².

• When Benton REA's board adopted its data center policy, by what vote, who signed request L0621, and under which statute the co-op is organized²¹. Searched: the co-op's published documents, newsletters and bylaws; route: O11, O10^21,92.

• Who governs TC West Richland I and TC Northwest Development today, and who owns or runs WKC31 Development⁹. The earlier brief lists WKC31 Development LLC as the buyer from TC West Richland 1 LLC¹¹⁴; the assessor record lists it as owner of a parcel⁹. Searched: registry mirrors; the state and Louisiana searches sit behind bot checks; route: O10, O15^9,14.

• Who held each Water Conservancy Board seat at the January 13, 2026 meeting where BENT-25-12 was decided¹⁸. Searched: all twelve board decisions; route: O13¹⁸.

• Whether any lawsuit names the city, Frank Tiegs LLC or the buyer companies, and whether anyone appealed S4-33044(B2)⁴⁹. Searched: the hearings office case search; route: O12, O8^9,49.

• Whether the Herald ran a hearing notice for the February 2025 hearings on TXT-0001-2025^1,2,36. Searched: the News Flash archive¹¹⁰; route: R1, R2, R18³⁶.

• Whether any sold parcel takes in the Mixed Use Transition strip or the small Urban Transition block next to the MU-LI band on the city's current zoning map¹¹⁷. Searched: county and city map layers, the map file; route: R24¹¹⁷.

• Who proposed the "supports data centers" line in the 2026 legislative priorities^28,43. Searched: the packets that preceded adoption; route: R23²⁸.

• The excise tax affidavits and any current-use continuance signed by WKC31⁹. Searched: Assessor roll and deeds; route: O2⁹.

• The subject of the October 6, 2026 executive session, the fate of Ordinances 27-26 and 28-26, and whether the approved September 15 minutes fix a line saying Brink, listed absent, read the consent titles^50,75. Route: the October 6 agenda and minutes, and R17⁷⁵.

• Who encouraged Salary Commission appointees Van Beek and Paden-Lilly to apply⁵¹. Searched: their letters; route: ask the clerk.

• Tony Carr's moratorium evidence package^50,71 and the open comments from the city's resident survey⁷¹. Searched: council packets and the survey dashboard; route: R15, R19⁵⁰.

• The June 27, 2001 Attorney General's office letter on council member and fire commissioner offices⁹⁹. Searched: quoted only in AGO 2016 No. 7⁹⁹; route: O16⁹⁹.

City requests go to City Clerk Stephanie Haug⁶⁰. Benton REA told the Tri-City Herald it is not subject to the Public Records Act²³, so a member demand under co-op law is the only route there. Court records fall under court rules.

• R1 | CED; City Clerk | TXT-0001-2025 application, fee receipt, notice mailings, website and news media notices, any affidavit of publication, comments, staff notes | Oct. 1, 2024 to Mar. 31, 2025³⁶

• R2 | City Clerk | Affidavits of publication and newspaper invoices for hearing notices (TXT-0001-2025, the ranch hearings) and for summaries of Ordinances 03-25 and 05-26 to 08-26 | Jan. 1, 2025 to June 30, 2026^3,7,36,46

• R3 | City Clerk | Notices, agendas, attendance and notes for Community Development Subcommittee meetings; committee assignment lists | Dec. 1, 2023 to June 30, 2026¹

• R4 | CED | Department of Commerce expedited review request and grant, notice and feedback, adoption transmittals for Ordinances 03-25 and 06-26 to 08-26 | Jan. 1, 2025 to June 30, 2026^3,7

• R5 | Finance; CED; Public Works | Executed Resolution 16-26 agreement and who signed "For" the mayor; invoices, payments, staff time, consultant bills, drafting file | Jan. 1, 2026 to date^5,14

• R6 | CED; Public Works | Pre-application records for any industrial or data center proposal on the ranch | Jan. 1, 2024 to date

• R7 | Mayor Brink, former Mayor Gerry, all seven councilmembers, Mendenhall, Slade, Foltz, Rio, Haug | Email, texts and calendars with Trammell Crow, CBRE, Tiegs, TRIDEC and the buyer companies; any copy of the purchase agreements | Jan. 1, 2024 to date^{1,12,50,60,62}

• R8 | City Clerk; City Attorney; Human Resources | Any nondisclosure agreement offered to or signed by a city official about a data center, Trammell Crow or the ranch | Jan. 1, 2024 to date⁵⁰

• R9 | Public Works | Water and sewer availability letters, capacity studies, any Tiegs notice assigning prepaid units to the survey parcels, the executed amendment to the Tiegs prepayment agreement, Well 13 status | Jan. 1, 2024 to date^17,32

• R10 | CED; Building Official and Fire Marshal; Public Works | Communications with Fire District 4 on a data center, fire flow or the ranch; draft revised interlocal agreement; one-acre station site | Jan. 1, 2024 to date^63,100

• R11 | CED; Public Works | Department routing and comments (Public Works, City Engineer, Building, Police, Finance) on TXT-0001-2025, TXT-0006-2026, the ranch EIS and Ordinances 06-26 to 08-26 | Oct. 1, 2024 to date^7,36,73

• R12 | Mayor; CED; Public Works | Communications with Benton REA or BPA about large loads, a data center or L0621 | Jan. 1, 2024 to date²¹

• R13 | City Clerk; City Attorney | Rio Foltz engagement letters, conflict waivers on data center matters, authority for Rio to sign for Foltz | Jan. 1, 2023 to date⁶²

• R14 | CED | Any written designation of the SEPA responsible official or of a signer for exempt segregations | Jan. 1, 2023 to date

• R15 | City Clerk; councilmembers | Tony Carr's evidence package⁵⁰; council email and letters containing "data center" | June 1, 2026 to date

• R16 | CED; City Clerk; Public Works | Who directed TXT-0006-2026, and its link to Ordinance 28-26 | Jan. 1, 2026 to date^50,73

• R17 | City Clerk | Any record naming the subject of the October 6, 2026 executive session | Sept. 15 to Oct. 6, 2026⁷⁵

• R18 | City Clerk; information technology staff | Website logs for posting hearing notices on TXT-0001-2025 and TXT-0006-2026; official posting places | Jan. 1 to Feb. 28, 2025; July 1 to Oct. 6, 2026^36,73,110

• R19 | City Clerk | Export of the city's resident survey, questions and open comments | Jan. 1 to May 31, 2026

• R20 | CED | The plat application letter, signer and reviewer notes for the ranch survey parcels; the Fire District 4 station short plat for comparison | Jan. 1, 2025 to May 31, 2026¹⁰¹

• R21 | Finance; City Clerk | Drafts of Ordinance 05-26 Exhibit B and any email on the label change | Apr. 1 to May 15, 2026⁴⁶

• R22 | City Clerk; CED | The Planning Commission's April 9, 2026 recording and recorder notes; any commissioner departure notice | Apr. 1 to May 31, 2026⁴⁵

• R23 | City Clerk; Mayor's office; Public Works | Drafts and email on the 2026 legislative priorities, including exchanges with the city's lobbyist | Aug. 1 to Oct. 31, 2025^28,43

• R24 | CED | The geographic information system (GIS) layer behind the city's official zoning map adopted May 5, 2026 | Current¹¹⁷

• R25 | City Clerk | Minutes and executive session agendas on the city's handling of the Growth Management Hearings Board case decided in the order dated 2018-03-26 | Oct. 1, 2017 to Apr. 30, 2018¹¹³

• O2 | Benton County Treasurer | Excise tax affidavits for the July 2026 deeds the earlier brief lists (Tiegs to TC West Richland 1, TC West Richland 1 to WKC31); any current-use continuance | July 2026¹¹⁴

• O3 | Benton County Public Works | The county's EIS comment file and later road review of the ranch | Jan. 1, 2025 to date

• O4 | Fire District 4 | Its Draft EIS response, level of service and capital documents, draft interlocal agreement, ranch and data center correspondence | Jan. 1, 2024 to date^63,100

• O6 | Benton PUD | Communications about the site, Trammel Crow or L0621 | Jan. 1, 2024 to date²¹

• O7 | Benton Clean Air Agency | Any notice of construction or contact about generators at the ranch | Jan. 1, 2024 to date

• O8 | Department of Ecology | S4-33044(B2) mailing list and date, any appeal, the notice text and any protests | Jan. 1, 2024 to date⁴⁹

• O9 | Department of Commerce | Planning submittals for Ordinance 03-25 and Ordinances 06-26 to 08-26 | Jan. 1, 2025 to June 30, 2026^3,7

• O10 | Secretary of State, Corporations | Annual reports and governors for TC West Richland I, TC Northwest Development and Frank Tiegs LLC; Benton REA's articles | Current filings^14,114

• O11 | Benton REA (member demand) | Board minutes adopting the large-load policy and approving L0621; the cost-recovery agreement | Jan. 1, 2024 to date^21,23

• O12 | Benton County Superior Court Clerk | Civil cases naming the city, Frank Tiegs LLC, TC Northwest Development, or the buyers named in the deeds the earlier brief lists (TC West Richland I, WKC31) | Feb. 2025 to date^9,114

• O13 | Benton County Water Conservancy Board | BENT-25 files, minutes of the January 13, 2026 decision meeting, attendance | Jan. 1, 2025 to date¹⁸

• O14 | State Auditor's Office | The November 26, 2025 letter to the Water Conservancy Board | 2025⁹⁸

• O15 | Louisiana Secretary of State | Any registration for WKC31 Development LLC (search by hand) | Current⁹

• O16 | Attorney General's Office | The June 27, 2001 letter on council member and fire commissioner offices | 2001⁹⁹

• AF/YR: acre-feet per year
• af/yr: acre-feet per year
• AI: artificial intelligence
• BPA: Bonneville Power Administration
• CFS: cubic feet per second
• cfs: cubic feet per second
• DNS: Determination of Non-significance
• EIS: Environmental Impact Statement
• ERU: equivalent residential unit
• LUPA: Land Use Petition Act
• MW: megawatts
• NDA: nondisclosure agreement
• OPMA: Open Public Meetings Act
• PUD: Public Utility District
• RCW: Revised Code of Washington
• REA: Rural Electric Association
• SEPA: State Environmental Policy Act
• SMR: small modular reactor
• TRIDEC: Tri-City Development Council
• UA: United Association
• WSBA: Washington State Bar Association

1. West Richland City Council minutes, February 18, 2025. https://www.westrichland.org/AgendaCenter/ViewFile/Minutes/_02182025-314 (primary)
2. West Richland Planning Commission minutes, February 13, 2025. https://www.westrichland.org/AgendaCenter/ViewFile/Minutes/_02132025-313 (primary)
3. Ordinance 03-25, signed copy. https://www.westrichland.org/DocumentCenter/View/2225/Ordinance-03-25-pdf (primary)
4. West Richland City Council minutes, April 21, 2026. https://www.westrichland.org/AgendaCenter/ViewFile/Minutes/_04212026-396 (primary)
5. Resolution 16-26 and reimbursement agreement with TC Northwest Development, Inc.. https://www.westrichland.org/DocumentCenter/View/2889/Resolution-16-26-pdf (primary)
6. Port of Seattle release on Trammell Crow Company and Des Moines Creek, August 8, 2017. https://www.portseattle.org/news/trammell-crow-company-selected-des-moines-creek-property-development-city-seatac (primary)
7. West Richland City Council minutes, May 5, 2026. https://www.westrichland.org/AgendaCenter/ViewFile/Minutes/_05052026-398 (primary)
8. Ordinance 07-26, signed copy. https://www.westrichland.org/DocumentCenter/View/2896/Ordinance-07-26-PDF (primary)
9. Benton County Assessor property records for the seven sold parcels. https://propertysearch.co.benton.wa.us/propertyaccess/Property.aspx?cid=0&year=2025&prop_id=323664 (primary)
10. West Richland City Council meeting video, January 6, 2026 (YouTube). https://www.youtube.com/watch?v=XHXGxPFpqfc (primary)
11. West Richland City Council meeting video, April 21, 2026 (YouTube). https://www.youtube.com/watch?v=mPg-vrsnpOk (primary)
12. West Richland City Council minutes, September 1, 2026. https://www.westrichland.org/AgendaCenter/ViewFile/Minutes/_09012026-423 (primary)
13. West Richland City Council packet, April 21, 2026. https://www.westrichland.org/AgendaCenter/ViewFile/Agenda/_04212026-396?packet=true (primary)
14. West Richland City Council packet, May 5, 2026. https://www.westrichland.org/AgendaCenter/ViewFile/Agenda/_05052026-398?packet=true (primary)
15. West Richland Municipal Code 16.02.030, exempt parcel segregations (eCode360). https://ecode360.com/49364624 (primary)
16. Ecology water right change application file, BENT-25, signature pages. https://appswr.ecology.wa.gov/docs/WaterRights/ScanToWRTS/CRO/pdf/6807334_7_1724000.pdf (primary)
17. Ecology decisions on BENT-25 changes, March 30, 2026. https://appswr.ecology.wa.gov/docs/WaterRights/ScanToWRTS/CRO/pdf/6807334_33_0330202620553.pdf (primary)
18. Benton County Water Conservancy Board records of decision, BENT-25-01 to -12. https://appswr.ecology.wa.gov/docs/WaterRights/ScanToWRTS/CRO/pdf/6807334_101_0122202627266.pdf (primary)
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111. West Richland Municipal Code 14.03.030, notice (eCode360). https://ecode360.com/49364286 (primary)
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117. City of West Richland official zoning map, adopted May 5, 2026. https://www.westrichland.org/DocumentCenter/View/114/Zoning-Map-PDF (primary)