On the agenda: Ypsilanti meeting — Data Center (Apr 15)

CITY OF YPSILANTI
PLANNING COMMISSION MEETING
Wednesday, April 15, 2026 @ 7:00 PM
Council Chambers
One South Huron, Ypsilanti, MI 48197

I.

CALL TO ORDER

II.

ROLL CALL
A.

III.

AGENDA APPROVAL
A.

IV.

Brian Jones-Chance, Chair
Matt Dunwoodie, Vice-Chair
Mike Davis Jr.
Phil Hollifield
Amanda Smith
Carl Scheir
Michelle Marin
Greg Woodring
Ingrid Lao

April 15th, 2026, Planning Commission Agenda

APPROVAL OF MINUTES
A.

March 18th, 2026, Planning Commission Draft Minutes

V.

PUBLIC COMMENT (3 MINUTES)

VI.

COMMITTEE REPORTS
A.

Non-Motorized Advisory Committee

VII.

PRESENTATIONS

VIII.

PUBLIC HEARING ITEMS

IX.

OLD BUSINESS
A.

X.

Zoning Text Amendment: Data Centers

NEW BUSINESS
A.

Zoning Text Amendment: Party Stores

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XI.

PUBLIC COMMENT (3 MINUTES)

XII.

ADJOURNMENT

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CITY OF YPSILANTI
PLANNING COMMISSION MEETING
DRAFT MINUTES
Wednesday, March 18th, 2026 @ 7:00 PM
Council Chambers
One South Huron, Ypsilanti, MI 48197

I.

Call to Order | 7:03 PM

II.

Roll Call
Brian Jones-Chance, Chair – Present
Matt Dunwoodie, Vice-Chair – Present
Mike Davis Jr. – Present
Phil Hollifield – Present
Amanda Smith – Excused Absence
Carl Schier – Present
Michelle Marin – Present
Greg Woodring – Present
Ingrid Lao - Excused Absence

Motion to excuse the absence of Commissioners Smith & Lao.
--Moved by Marin. Seconded by Hollifield. Yays – 7, Nays – 0, motion carries

III.

Agenda Approval
March 18th, 2026, *Amended Agenda
*Staff requested the addition of a presentation to provide an update on projects within the
Planning Department.

--Amendment accepted by Commissioner Dunwoodie.
Motion to approve the amended agenda.
--Moved by Dunwoodie. Seconded by Marin. Yays – 7, Nays – 0, motion carries

IV.

Approval of Minutes
February 18th, 2026, Planning Commission Draft Minutes.

Page 3 of 91

Motion to approve the February 18th, 2026, draft minutes as presented.
--Approved by Commissioner Jones-Chance, motion carries

V.

Public Comments
Motion to open public comments to the Planning Commission.
--Moved by Davis Jr. Seconded by Woodring. Yays – 7, Nays – 0, motion carries
No members of the public spoke.

Motion to close public comments to the Planning Commission.
--Moved by Woodring. Seconded by Davis Jr. Yays – 7, Nays – 0, motion carries

VI.

Committee Reports
Non-Motorized Advisory Committee (NMAC) – Commission will be meeting on
March 19th.

VII. Presentations
A. General Planning Department Updates - Staff provided updates on numerous
Planning Department projects, including zoning text amendments, previously
approved projects, the master plan, etc).

VIII. Public Hearing Items
A. Zoning Text Amendment: Harm Reduction
Staff provided an overview of the proposed amendments, including the removal of the
prohibition on drug checking services for harm reduction facilities.
Discussion focused on drug checking services, inconsistencies in buffer requirements,
and whether separate or shared use standards should apply to harm reduction and
substance use disorder facilities.

Public Hearing:
Motion to open the public hearing to the Planning Commission.
--Moved by Hollifield. Seconded by Woodring. Yays – 7, Nays – 0, motion
carries

Page 4 of 91

No members of the public spoke.

Motion to close public hearing to the Planning Commission.
--Moved by Hollifield. Seconded by Woodring. Yays – 7, Nays – 0, motion
carries
Decision:
Motion to recommend City Council approve the proposed text amendment to
Sections 122-203, 122-446, 122-451, 122-461, and 122-555, with the following
amendments as discussed in the meeting; to define drug checking services as an
allowed use within the harm reduction service facility definition, and provide a
subsection b under 122-555 to establish use-based buffer regulations for harm
reduction service facilities; and with the following findings:
1. The proposed amendment is consistent with the guiding values of the
Master Plan; and
2. The proposed amendment is consistent with the intent of this Zoning
Ordinance; and
3. The proposed amendment will enhance the functionality, transportation
network or character of the future development in the City; and
4. The proposed amendment will preserve the historic nature of the
surrounding area and of the City; and
5. The proposed amendment will not result in the creation of significant
nonconformities in the City.
--Moved by Marin. Seconded by Woodring. Yays – 7, Nays – 0, motion carries
Brian Jones-Chance, Chair – Support
Matt Dunwoodie, Vice-Chair – Support
Mike Davis Jr. – Support
Phil Hollifield – Support
Carl Schier – Support
Michelle Marin – Support
Greg Woodring – Support

B. 15 S. Grove | Group Childcare Home Play Area | SLU SP
Staff presented the request for use of a vacant lot as an outdoor play area associated with
an approved group childcare home at 11 South Grove.
Discussion focused on fencing, screening requirements, and cross-lot access between
parcels.

Page 5 of 91

Public Hearing:
Motion to open the public hearing to the Planning Commission.
--Moved by Marin. Seconded by Woodring. Yays – 7, Nays – 0, motion carries
No members of the public spoke.

Motion to close public hearing to the Planning Commission.
--Moved by Marin. Seconded by Hollifield. Yays – 7, Nays – 0, motion carries
Special Land Use Permit Decision:
Motion to approve with conditions the special use permit for the group
childcare home outdoor play area at 15 S. Grove Street with the following
findings:
Findings:
1. The application substantially complies with Sections 122-324 and 122-326.
2. The proposal serves as the designated outdoor play area for the group
childcare home at 11 S. Grove Street and meets all zoning requirements.
Conditions:
1. The special use permit is subject to site plan approval.
--Moved by Dunwoodie. Seconded by Marin. Yays – 7, Nays – 0, motion carries
Brian Jones-Chance, Chair – Support
Matt Dunwoodie, Vice-Chair – Support
Mike Davis Jr. – Support
Phil Hollifield – Support
Carl Schier – Support
Michelle Marin – Support
Greg Woodring – Support

Site Plan Decision:
Motion to approve with conditions the site plan for the group childcare
home outdoor play area at 15 S. Grove Street with the following findings and
conditions:
Findings:
1. The application substantially complies with Sections 122-309 and 122-311.

Page 6 of 91

Conditions:
1. The proposed outdoor play area shall be screened in accordance with Section
122-442(b).
--Moved by Dunwoodie. Seconded by Marin. Yays – 7, Nays – 0, motion carries
Brian Jones-Chance, Chair – Support
Matt Dunwoodie, Vice-Chair – Support
Mike Davis Jr. – Support
Phil Hollifield – Support
Carl Schier – Support
Michelle Marin – Support
Greg Woodring – Support

IX.

Old Business
A. Zoning Text Amendment: Revision of Approved Plans
Staff presented a detailed framework for categorizing revisions to approved planned unit
developments (PUDs) into three tiers: major revisions, minor revisions requiring Planning
Commission approval, and minor revisions eligible for administrative approval.
Discussion included:
• Clarification of what constitutes a "major" revision, including increases in intensity,
density, building size beyond 10%, changes to access, and substantial alterations to
site design or character.
• Establishing thresholds for "minor" revisions (e.g., ≤10% changes to building
area/height, modest parking or circulation adjustments, and limited reductions in
landscaping).
• Administrative flexibility for small-scale changes (e.g., ≤5% dimensional changes,
minor relocation of features, material substitutions, small accessory structures, and
minor renewable energy installations).
• Allowing limited additional uses within existing buildings (up to 10% for Planning
Commission review and 5% administratively) to support adaptive reuse and mixeduse functionality.
• Ensuring the ordinance avoids requiring full PUD amendments for changes that are
consistent with the Master Plan and the original intent of approval.
The Commission took no formal action, but amended language will be brought forth to next
month’s meeting.

B. Zoning Text Amendment: Data Centers

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Staff introduced the need for a new zoning text amendment addressing data centers, noting
that the current ordinance lacks specific standards for this use.
Discussion included:
• The absence of a clear regulatory framework for data centers within the ordinance.
• Anticipated need to address key impacts such as energy consumption, infrastructure
demands, noise, and site design.
The Commission took no formal action, but amended language will be brought forth to next
month’s meeting.

X.

New Business – None.

XI.

Public Comments
Motion to open public comments to the Planning Commission.
--Moved by Dunwoodie. Seconded by Woodring. Yays – 7, Nays – 0, motion carries
No members of the public spoke.

Motion to close public comments to the Planning Commission.
--Moved by Dunwoodie. Seconded by Hollifield. Yays – 7, Nays – 0, motion carries

XII. Adjournment | 9:09 PM
Motion to adjourn.
-Moved by Commissioner Jones-Chance. Yays – 7, Nays – 0, motion carries

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City of
Ypsilanti
Pride. Diversity. Heritage.

Zoning Text Amendment: Data
Centers
Attachments:
-

APA Zoning Practices – Data Center | Article
Urban Land Institute – Data Centers | Article
East Tawas Draft Data Center Ordinance
Unknown Community Draft Data Center Ordinance
Green Oak Township Draft Data Center Ordinance
Map of Parcels Larger than 5 Acres
Zoning Text Amendment Staff Report
Last Month’s Correspondence with City Attorney

Ff

1
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OCTOBER 2025 | VOL. 42, NO. 10

ZONING
PRACTICE

Unique Insights | Innovative Approaches | Practical Solutions

The Physical Footprint
of Artificial Intelligence

In this Issue: What Are the Physical Needs of AI? | How Is AI Infrastructure Regulated (or Not)? | What Should Planners Be Thinking About? | Where Can Planners Learn
More?

Page 10 of 91

The Physical Footprint
of Artificial Intelligence
By Charlie Nichols, aicp
Every time you ask ChatGPT, Gemini, or Claude a question, you are tapping into a
sprawling, power-hungry network of machines. Somewhere, a data center’s processors
are whirring, fans are spinning, and megawatts of electricity are flowing.
Artificial intelligence (AI) may feel virtual, but its footprint is intensely physical.
Behind every chatbot interaction, predictive algorithm, or autonomous system lies
a vast network of data centers, power
generators, and electricity transmission
and distribution infrastructure. As vast as it
is now, the demand for computing power
is growing at an exponential rate, and local
zoning is on the front lines.

This issue of Zoning Practice explores
the physical effects of AI deployment and
highlights core considerations for local
planning and zoning. It begins with a summary of the land use characteristics of the
system of data centers that host and serve
contemporary AI models before highlighting noteworthy regulatory approaches and
areas of opportunity for zoning updates
and land use decision-making processes.

Data center
infrastructure
in the United
States, 2025
(Credit: NREL)

Zoning Practice | American Planning Association | October 2025 2

Page 11 of 91

What Are the Physical Needs of
AI?

When we think about artificial intelligence, we often imagine abstract ideas
or algorithms, software, or maybe a chat
assistant or a robot. But AI is deeply physical. It runs on powerful hardware that
lives in large buildings, draws enormous
amounts of electricity, and requires robust
infrastructure to keep it cool and operational. These needs are shaping land use
decisions in ways many communities have
never dealt with before.
AI Lives in Data Centers
The primary home of AI is the data center.
These are large, sometimes windowless,
buildings filled with servers, networking
equipment, and backup systems. While
some are sleek and high-tech, many look
like simple warehouses. But inside, the
technology is anything but simple.
AI workloads require far more computational power than traditional cloud
computing. That means more servers
packed with graphics processing units
(GPUs), which are optimized for machine
learning tasks. These GPUs are energy-intensive and generate a significant amount
of heat (Shehabi et al. 2024; Casey 2025).
This is why the design, location,
and infrastructure of data centers have
become such a big deal. For example,
Meta’s Altoona, Iowa, data-center campus
has more than five million square feet of
space and is still growing (Miller 2022).
Data centers themselves fall into several distinct categories. Edge or micro
facilities are the smallest, often modular
container-sized enclosures ranging from
a few hundred to a few thousand square
feet. Enterprise data centers, typically
operated by corporations or universities,
can range from about 5,000 to 50,000
square feet, sometimes larger. Colocation
facilities lease space to multiple tenants and often fall between 50,000 and
600,000 square feet, with many averaging
around 150,000 square feet. At the largest
scale are hyperscale data centers, typically
built by major cloud or AI providers, which
can easily reach hundreds of thousands
of square feet per building and exceed
one million square feet across a campus
(Zhang 2023).
While many forecasts focus on power

demand rather than square footage, it is
possible to translate one into the other.
Deloitte estimates that AI-driven data
centers could require up to 123 gigawatts
(GW) of capacity in the U.S. by 2035, compared to roughly 4 GW today (Stansbury
et al. 2025). Real-world projects suggest
that every megawatt of IT load requires
between 5,000 and 12,000 square feet of
total building area. Applying that ratio to
123 GW implies a national buildout of 615
million to 1.48 billion square feet of data
center space, equivalent to about 22 to
53 square miles. Land use estimates point
in a similar direction, with recent projects averaging 0.5 to 1.5 acres per MW,
which would translate to roughly 96 to
288 square miles of U.S. land devoted to
AI-related data center campuses by 2035
(Stansbury et al. 2025).

AI Needs Lots of Electricity
Power demand is one of the most critical limiting factors in scaling AI. The
U.S. Department of Energy’s Secretary of
Energy Advisory Board notes that legacy
hyperscale data centers have typically
connected at 20–50 megawatts (MW),
but utilities are now receiving AI-driven
connection requests for single campuses
of 300–1,000 MW (2024). To put the
low end of that new range in context, a
300 MW facility running around the clock
would consume about 2.6 terawatt-hours
a year—roughly the annual electricity
use of 250,000 U.S. homes (calculated

A proposed 612acre hyperscale
data center
campus in Cedar
Rapids, Iowa
(Credit: QTS)

Zoning Practice | American Planning Association | October 2025 3

Page 12 of 91

with the U.S. EIA average of 10,500 kWh
per household). These unprecedented
loads are forcing planners, utilities, and
regulators to rethink siting, transmission
capacity, and community-impact mitigation.
This demand is driving data centers
to locate near existing transmission infrastructure, substations, or power plants.
In some cases, new substations or transmission lines are being proposed just to
support AI infrastructure. Local planners
are being asked to approve not just buildings, but energy projects with regional
impacts.
There is also growing concern about
the climate impacts of AI. Researchers
estimate that the cumulative carbon emissions from AI models could reach 3.66
to 8.72 million tons in the U.S. alone—the
equivalent of driving an average gasoline-powered car nine to 22 billion miles
(Ding et al. 2025; USEPA 2024). This has
led to pressure for data centers to run on
renewable energy, adding another layer
of land use complexity as solar or wind
farms are proposed nearby or colocated
together with data centers.

Annual Water Withdrawal (Millions of Gallons)

Top-five U.S.
Google data
centers by annual
water withdrawals,
2024 (Credit:
Google’s 2025
Environmental
Report)

1,600
1,400
1,200
1,000

AI Needs Water and Cooling
All that power generates heat, and that
heat has to go somewhere. Most data
centers use a combination of air- and
watercooling systems. Some of the largest
AIfocused facilities can consume hundreds
of thousands of gallons of water per day

AI Needs Fiber and Connectivity
Finally, AI infrastructure depends on highspeed fiberoptic connections. Training
models and delivering AI services both
require fast, reliable data transmission.
This can drive the need for new fiber lines,
telecom infrastructure, or even small-cell
installations in rural or suburban areas
(RVA LLC 2025; Walker 2024).
It’s not just big cities seeing these
investments. Some rural areas are gaining
interest from AI developers because they
offer space, lower land costs, and cooperative local governments—provided they
can offer fiber access and a willing utility
partner.

How Is AI Infrastructure
Regulated (or Not)?

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800
600

for evaporative cooling (Lei et al. 2025;
Shehabi et al. 2024; Selsky 2022). That’s
raising concerns in water-scarce regions
or places where water infrastructure is
already stretched thin.
For example, in The Dalles, Oregon, a
dispute between Google and the city over
water use became national news when
the city council approved a water agreement to support Google’s data center
expansion, despite local concerns about
long-term water availability (Selsky 2022).
Water and cooling infrastructure also
raise siting questions. Should data centers
be allowed in areas with limited water supply? What happens when a tech company
becomes one of the largest users of
municipal water? These questions are
starting to reach planning commissions
and city councils.

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Golf Courses

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Golf Courses

400
200
0
Council Bluffs, Mayes County,
Berkeley
Papillion, NE The Dalles, OR
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OK
County, SC
Google Data Center Locations

If your city or county does not already
have a data center, just wait. The odds
are increasing that a tech company, or the
utility that serves them, will soon come
knocking. Yet most local governments
are not fully prepared to regulate AI infrastructure. In many places, the regulatory
framework is either nonexistent or built for
a different era of technology.
Zoning Codes Rarely Mention AI
or Data Centers
Many zoning codes still make no explicit
reference to “artificial intelligence” or even
to “data centers.” Where definitions are

Zoning Practice | American Planning Association | October 2025 4

Page 13 of 91

absent, planners may choose to slot these
facilities into broad buckets such as warehousing, light-industrial, or public-utility
uses, even though the buildings may be
packed wall-to-wall with servers instead of
pallets.
Yet these facilities behave very differently from the categories they’re often
shoehorned into, and there are many
reasons why local governments may want
to specifically define data center uses
(Morley 2022). Their continuous operation
demands megawatts of electricity and,
in many climates, hundreds of thousands
of gallons of cooling water per day; the
equipment generates heat and noise; and
the employment footprint is minimal. When
such impacts are overlooked, communities can be blindsided—as happened
in Prince William County, Virginia, where
approval of a massive datacenter corridor
sparked backlash over noise, power delivery, and land use compatibility.
Recognizing this mismatch, an
increasing number of jurisdictions have
begun to write data-center-specific rules.
Loudoun County, Virginia, imposes
façade, screening, lighting, and pedestrian-connectivity standards on by-right
data centers to blunt visual impacts while
leveraging their tax base (§4.06.02).
Prince William County uses a Data Center
Opportunity Zone Overlay to funnel projects to infrastructure-served parcels and
require design review (§32-509). Missoula
County, Montana, offers a different model.
The county’s ordinance, crafted for cryptocurrency mines, confines those operations
to industrial zones and requires them to
offset 100 percent of their electricity use
with renewable energy (§5.10). Because
cryptocurrency mines and large‑scale
data centers both run continuously, draw
high‑density power, and employ few
on‑site workers, planners can adapt the
same toolkit—clear land use definitions,
targeted overlay districts, and energy‑focused performance standards—to data
centers when communities want comparable safeguards.
Looking ahead, AI training clusters
dwarf the loads discussed in 2022, with
utilities now fielding single-campus interconnection requests of 300 MW and
more. The zoning fundamentals remain the
same, but the stakes are higher. Without

proactive definitions, locational criteria,
and impact standards, local governments
risk conceding critical decisions about
land, water, and grid capacity to developers’ timetables rather than community
goals.

Many AI Facilities Are Allowed by
Right
In areas that do allow data centers
by right, local officials often have little
authority to influence their design or siting (Morley 2022). Developers may be able
to build massive facilities with only administrative approval. If the project complies
with the basic zoning and building code, it
can move forward, even if it brings significant impacts to neighboring properties or
the local infrastructure system.
This hands‑off, by‑right approach can
leave neighbors in the dark when a campus that draws 100 MW or more of power
is permitted the same way a warehouse
is. Such facilities may also require hundreds of thousands of gallons of cooling
water per day and generate continuous
low‑frequency noise from chillers, pumps,
and backup generators (Van Geet and
Sickinger 2024). Without a public‑hearing
trigger, residents may not learn what is
coming until the bulldozers roll.
That said, relying on discretionary use permits alone is not a perfect
fix. Case‑by‑case approvals can introduce
uncertainty, increase timelines, and duplicate reviews that utilities already perform
when they decide whether to supply the
necessary electricity and water. A more
balanced strategy is to embed objective,
use‑specific standards (e.g., caps on
sound at the property line, requirements
for renewable‑energy procurement, and

Data Center
Alley in Loudoun
County, Virginia
(Credit: Gerville/
iStock/Getty
Images Plus)

Zoning Practice | American Planning Association | October 2025 5

Page 14 of 91

water‑recycling targets) directly into the
zoning code. Guidance from the Urban
Land Institute shows how clear definitions,
overlay districts, and measurable performance thresholds can give developers
predictability while still protecting community interests (Miet 2024). By pairing these
standards with early coordination among
planners, utilities, and residents, communities can address local impacts without
resorting to duplicative or open‑ended discretionary reviews.
Infrastructure Approvals May Be
Handled Separately
Adding to the complexity, the infrastructure
needed to support AI such as transmission lines, substations, power generation
facilities, battery energy storage. and fiber
installations is often regulated under different frameworks. Utilities may have their
own review and siting authority at the state
level, which can bypass local land use
processes entirely.
Large solar or wind projects, for example, are pre-empted from local control in
more than 20 U.S. states, leaving local
governments to vet the data-center building, while the power generation facility that
feeds it is debated elsewhere (Gomez and
Morley 2023; Morley 2025). Fragmented
approvals make it hard for planners to tally

cumulative effects such as substations,
access roads, or groundwater withdrawals.
Battery-energy-storage systems
(BESS) create another layer of complexity,
and a clear trend of data centers colocating BESS on-site is accelerating
(ZincFive 2024). Some states exempt utility-scale BESS that are colocated with
generation assets, while others treat them
as industrial equipment needing only an
electrical permit. Where local authority
does apply, recent guidance recommends
clear definitions, district regulations, and
objective safety standards, thermal-runaway monitoring, minimum setbacks, and
emergency-response plans to avoid
ad-hoc hearings (Ross and Vadali 2024).
Developers are now bundling data
centers with on-site renewables and storage in microgrid “energy parks,” aiming
to bypass long interconnection queues
and control energy costs. Recent projects in Texas and Virginia pair hundreds
of megawatts of generation and storage
with adjacent server halls, creating hybrid
campuses that straddle state energy-facility review, regional transmission rules, and
local zoning (DiGangi 2025). To keep pace,
planners can identify jurisdictional triggers
early, embed measurable performance
standards (e.g., noise caps, screening, or
renewable-energy sourcing) in their codes,

The Eland Solarplus-Storage
Center in Kern
County, California
(Credit: The Desert
Photo/iStock/Getty
Images Plus)

Zoning Practice | American Planning Association | October 2025 6

Page 15 of 91

and coordinate with utilities so local and
state reviews proceed on aligned timelines.
Environmental Review Is
Inconsistent
Environmental review of AI infrastructure
also varies widely. In states that require
environmental impact statements (EIS),
large-scale data centers may undergo
detailed scrutiny. But in states without EIS
laws, or for smaller projects, there may be
minimal analysis of water use, energy consumption, or greenhouse gas emissions
(Morris 2024).
Even where review is required, the
focus may be on the building itself, rather
than the full ecosystem of impacts. For
example, if a local code does not require
review of off-site power infrastructure or
supporting utility upgrades, critical issues
related to energy delivery, environmental
impact, or long-term capacity may fall
through the cracks.
Local Governments Are Starting
to Catch Up
Local governments are no longer standing
still while hyperscale campuses spring
up at the edge of town. Since 2023, a
wave of city councils, county boards, and
planning commissions have begun moving data centers out of catch‑all industrial
categories and into their own, better‑defined regulatory boxes. Some jurisdictions,
such as Atlanta, now require special‑use
permits tied to energy, water, and noise
studies (Ordinance 25-O-1063). Others,
such as Cedar Rapids, Iowa, leverage
community‑benefit agreements to ensure
local reinvestment when a project wins
approval (Pratt 2025).
Approaches vary, but the trend is
unmistakable: Communities are adopting
objective, use‑specific standards rather
than relying solely on ad‑hoc discretionary
permits. Some ordinances steer projects
into infrastructure‑served corridors, others
set caps on sound and water use, and a
growing number link approvals to renewable energy procurement or on‑site
battery storage. Table 1 highlights seven
recent examples illustrating the breadth of
new zoning language, overlay districts,
and design guidelines that together show
local governments are indeed catching up.

Table 1. Examples of Recent Local Regulatory Updates for Data Centers

Jurisdiction
Atlanta, GA

Brainerd, MN

Chandler, AZ

Tempe, AZ

Phoenix, AZ

Sugar Grove, IL

Frederick County,
MD

How it regulates data-center
impacts
Requires a special-use permit
for every new data center and
empowers the city council to
review water-consumption, energyefficiency, and noise-mitigation plans
(Ordinance 25O1063, 2024)
Prohibits data centers unless the
planning commission approves
a conditional-use permit that
addresses cooling noise and utility
demand (Ordinance No. 1581, 2025)
Adds a data center use category;
limits the use to Planned Area
Development zones and sets size,
generator-testing and water-recycling
standards (Ordinance No. 5033, 2022)
Requires a water use plan and
enhanced setbacks next to homes
and schools, and “innovation hubs”
(Ordinance No. O2025-23, 2025)
Defines “data center,” restricts
locations, and introduces design
standards such as façade articulation
and noise studies (Ordinance
G-7396, 2025)
Creates a dedicated district with
height limits, façade screening, and
a master-utility-plan requirement
(Ordinance No. 2022-1206B, 2022)
Establishes an overlay zone that
limits where data centers can be built
(Bill No. 25-05, 2025)

What Should Planners Be
Thinking About?

Artificial intelligence may sound futuristic,
but the decisions that shape its physical
footprint are being made today. Local
governments that wait too long to prepare
may find themselves reacting to projects
rather than guiding them. So what should
planners be thinking about now?
Think About Scale
AI infrastructure often hides in plain sight
until its true footprint emerges. What looks
like a single “warehouse” can blossom
into a portfolio buildout—multiple server
Zoning Practice | American Planning Association | October 2025 7

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halls, two substations, a battery yard, and
a 30-inch water main, all staged over a
decade (USDOE SEAB 2024). To avoid
approving these megaprojects one slice at
a time, some jurisdictions now demand a
phased master plan up front. For example,
Loudoun County, Virginia, requires every
data-center rezoning to include a “Data
Center Development Plan” showing the full
buildout of power feeds, cooling infrastructure, and utility corridors before the first
site plan is approved (2025).
Regional utilities are following suit by
running scenario-based load models to
test whether transmission and groundwater supplies can keep up. A 2024 white
paper by Energy + Environmental Economics describes how such models
informed Portland (Oregon) General
Electric’s latest integrated-resource plan
and helped local planners identify future
right-of-way corridors for two new 230-kV
lines (Riu et al. 2024). By asking for phased
utility exhibits and participating in utility
load-growth scenarios, planners can make
sure each new server hall fits into a system-wide picture rather than becoming an
isolated surprise.

Many comprehensive plans still
treat “technology infrastructure”
as an afterthought, yet data
center proposals are now shaping
decisions on land supply, energy
policy, water allocation, and
broadband.

Think About Alignment With Your
Plans
Many comprehensive plans still treat
“technology infrastructure” as an afterthought, yet data-center proposals are
now shaping decisions on land supply, energy policy, water allocation, and
broadband. Start by inventorying where
AI-related facilities touch existing plan
elements—utilities, environmental stewardship, economic development—and flag the
gaps.
One emerging best practice is to link

data-center approvals directly to community climate goals. Embedding such
benchmarks in comprehensive plans or
codes gives planners clear decision criteria and ensures that new AI infrastructure
advances, rather than conflicts with, local
resiliency objectives.
Plans can also weave data-center
growth into broadband and workforce
strategies. The U.S. Department of Energy’s 2024 report on AI infrastructure
recommends that local governments coordinate land-use designations with state
broadband-expansion maps so that fiber
corridors serving data centers double as
backbone routes for underserved neighborhoods (USDOE SEAB 2024). Aligning
these layers up front helps planners
negotiate public-benefit clauses—such as
dark-fiber setasides or training programs,
rather than scrambling for concessions
late in the process.
Updating your plan first and then
adopting measurable standards that flow
from it gives applicants clarity, while ensuring projects advance the community’s
long-term vision.
Think About Infrastructure
Capacity
AI campuses can overwhelm local utilities
faster than many other land uses. Virginia’s Joint Legislative Audit and Review
Commission estimates that data centers
will require 11 gigawatts (GW) of new electric generation and transmission in that
state alone by 2035, roughly one-third of
Dominion Energy’s entire current system
(VJLARC 2024). National modeling by
Energy + Environmental Economics shows
a similar surge, with some balancingareas
seeing load grow 25 percent in a single
decade under an “AI-high” scenario (Riu et
al. 2024).
Water systems face parallel stress. At
Google’s complex in The Dalles, Oregon,
public records show cooling demand
could top one-quarter of the city’s current supply, prompting a 2023 agreement
that pauses future phases unless new
wells come online (Selsky 2022). Quincy,
Washington, responded to similar pressures by creating a special water rate
class and meter fee for data centers to
fund infrastructure upgrades (2025). These
examples point to tools planners can

Zoning Practice | American Planning Association | October 2025 8

Page 17 of 91

The Three Mile
Island nuclear
power plant
in Middleton,
Pennsylvania,
which is coming
back online to
power Microsoft
data centers
(Credit: gsheldon/
iStock Editorial/
Getty Images Plus)

adopt: cumulative-demand studies
embedded in utility master plans, tiered
rate structures that recover capital costs,
and permit conditions that link new construction to confirmed water-capacity
projects.
Electric and water systems are only
part of the picture. Broadband providers
may need additional conduit banks, and
public works departments often discover
that construction traffic surpasses roaddesign volumes. Objective, use-specific
standards, such as requiring a utilityinfrastructure plan that maps ultimate
substations, mains, and fiber routes, plus
haul-route and pavement-repair agreements, give planners leverage without
duplicating state or utility reviews.
Think About Cumulative Impacts
A single 30 MW data center can feel
benign, yet clusters of 10 or more along
one corridor may push peak electric
load past a gigawatt, double truck traffic
during construction, and raise ambient
sound by up to 10 dBA at nearby homes
(VJLARC 2024). Project-by-project review
often misses these system-level effects, so
several jurisdictions now require applicants
to look beyond their parcel lines.
Clustering can also amplify benefits

if managed deliberately. Developers in
Texas and Virginia now pair multiple
server halls with a shared microgrid that
combines on-site solar, wind, and battery
storage—an “energy-park” model that
eases interconnection delays and helps
regions meet renewable-energy goals
(DiGangi 2025). By mapping preferred
corridors for both data centers and their
supporting infrastructure, planners can
steer growth to areas where capacity,
compatibility, and community returns align.
Think About Equity and
Community Benefits
Data-center projects promise major capital
investment but generate few long-term
jobs and can offload noise, truck traffic,
and resource use onto nearby neighborhoods. Additionally, new cost analyses
show that ordinary ratepayers are already
footing most of the bill for AI’s voracious
appetite for electricity.
Monitoring Analytics, the independent
market monitor for PJM Interconnection,
the largest regional transmission organization in the U.S., calculated that between
2024 and 2025 data-center electricity
demand added about $25 to the typical
household’s monthly bill (Biryukov 2025).
PJM now projects that AI and data-center
Zoning Practice | American Planning Association | October 2025 9

Page 18 of 91

A North Dakota
data center using
nonconductive
fluid to cool
servers rather
than air or
water cooling
systems (Credit:
halbergman/E+)

demand will double the region’s energy
use by 2033, whereas growth would have
been only 15 percent by 2040 without new
campuses (JLARC 2024).
In response to this and other similar
projections of effects on ratepayers, lawmakers in New Jersey (AB 5466), Oregon
(HB 3546), and other states have introduced bills or tariffs to place data centers
in a separate rate class or require them to
“bring their own clean power,” so everyday customers are not forced to subsidize
the electricity needs of trillion-dollar tech
companies (Levy 2025). More communities are also moving to tie approvals to
arrangements that deliver measurable
local benefits.
For example, Cedar Rapids, Iowa,
required QTS to sign a community
benefits agreement (CBA) that will
return about $18 million over 20 years for
workforce training, broadband expansion, and green-infrastructure projects
(Pratt 2025). Legal guidance stresses clear
milestones, third-party verification, and
enforcement clauses to keep such agreements credible (Eisenson 2023).
Meanwhile, Quincy, Washington, created a special water rate class for data
centers in 2024, adding higher volumetric
charges and meter fees earmarked for
new wells and main upgrades. Targeted
surcharges turn one user’s high demand
into system-wide resilience.
By weaving CBAs and host-community fees into zoning approvals or
development agreements, planners can
ensure that AI infrastructure acts as a

catalyst for broader community gain rather
than an enclave of private benefit.

Where Can Planners Learn
More?

As artificial intelligence infrastructure
expands, planners have a growing need to
stay informed about what these facilities
are, how they function, and how to plan for
them thoughtfully. The good news is that
several helpful resources already exist, and
more are emerging every year.
Follow the Energy
Many AI-related land use challenges stem
from energy demand. That means energy
planning organizations are a good place
to start. Resources from the U.S. Department of Energy, National Renewable
Energy Laboratory, and Lawrence Berkeley National Laboratory offer insights into
data center energy use, grid impacts, and
cooling technologies (Shehabi et al. 2024;
USDOE SEAB 2024; Van Geet and Sickinger 2024).
State and regional energy offices are
also useful partners. They can help planners understand energy trends, forecasted
demand, and opportunities to align AI-related development with state energy goals.
Watch the Water
Water use is another key issue, especially
in places facing drought or groundwater
depletion. Reports from the U.S. Environmental Protection Agency, as well as local
water utilities and watershed management
agencies, can help assess water-related
impacts of AI infrastructure.
Planners can also look to academic
and journalistic research on water use in
cooling systems, which varies significantly
based on the type of cooling and climate
zone (Berreby 2024).
Track Technology and Land Use
Trends
For a broad view of how technology
affects land use, the Lincoln Institute of
Land Policy and the Urban Land Institute
have both published helpful materials.
These organizations explore how emerging technologies from AI to autonomous
vehicles are reshaping cities, infrastructure, and land markets.

Zoning Practice | American Planning Association | October 2025 10

Page 19 of 91

Local case studies can also be
instructive. Some jurisdictions have started
sharing lessons learned from planning
for large-scale data centers or tech campuses. For example, Loudoun (2024; 2025)
and Fairfax (2024) Counties in Virginia offer
planning documents and staff reports that
shed light on real-world challenges and
solutions.
Build Cross-Sector Relationships
Planning for AI infrastructure requires collaboration. It touches on land use, utilities,
economic development, and environmental protection. Building relationships with
energy providers, water utilities, economic
development groups, and regional planning agencies can help planners spot
opportunities and anticipate challenges.
Conferences like the American Planning Association’s National Planning
Conference, Grid Forward, or Smart Cities
Connect often include sessions on technology infrastructure. These events are a
great way to hear from peers and industry
experts.
AI infrastructure is no longer a faroff idea; it’s already shaping land use
decisions in communities across the
country. For planners, this presents both
challenges and opportunities. By understanding what AI infrastructure is, what it
requires, and how it fits into broader planning goals, local governments can prepare
for development that is sustainable, equitable, and forward-looking.
As with many emerging trends, the
best path forward is to stay curious, build
partnerships, and think holistically. AI may
be powered by algorithms, but the future it
creates will depend on human decisions,
including the choices planners make
today.

References and Resources
Berreby, David. 2024. “As Use of AI Soars, So
Does the Energy and Water It Requires.” Yale
Environment 360, February 6.
Biryukov, Nikita. 2025. “Power Companies Warn
Lawmakers About Their Plans to Tackle Rising
Bills.” New Jersey Monitor, April 25.
Casey, Evan. 2025. “Microsoft Built Five Data

Center Campuses in This Iowa City. Here’s
What Wisconsin Can Expect.” Wisconsin Public
Radio, May 15.

About the
Author

DiGangi, Diana. 2025. “Microgrid ‘Energy
Parks’ Could Ease Strain from Rising Power
Demand, Report Says.” Utility Dive, July 23.
Ding, Zhaohao, Jianxiao Wang, Yiyang Song,
Xiaokang Zheng, Guannan He, Xiupeng
Chen, Xiupeng Chen, Tiance Zhang, Wei-Jen
Lee, and Jie Song. 2025. “Tracking the Carbon
Footprint of Global Generative Artificial Intelligence.” The Innovation 6(5): 100866.
Eisenson, Matthew. 2023. “Experts Identify
Best Practices for Negotiating and Drafting
Community Benefits Agreements.” Climate
Law, September 27.
Fairfax (Virginia) Department of Planning Development, County of. 2024. Data Centers Report
and Recommendations.
Gomez, Alexsandra, and David Morley. 2023.
Solar@Scale: A Local Government Guidebook
for Improving Large-Scale Solar Development
Outcomes. Chicago: American Planning Association; Washington, DC: International City/County
Management Association.
Lei, Nuoa, Jun Lu, Arman Shehabi, and
Eric Masanet. 2025. The Water Use of Data
Center Workloads: A Review and Assessment
of Key Determinants. Berkeley, CA: Lawrence
Berkeley National Laboratory.
Levy, Marc. 2025. “As Electric Bills Rise, Evidence
Mounts That Data Centers Share Blare. States
Feel Pressure to Act.” Associated Press, August 8.
Loudoun (Virginia), County of. 2024. “Data Center Growth and Energy Constraints.” Board of
Supervisors Transportation and Land Use Committee Information Item, June 20.

Charlie Nichols,
aicp, is the Director
of Planning and
Development
for Linn County,
Iowa. He leads
a 15-person
department
and has written
pioneering zoning
ordinances for
utility-scale solar,
nuclear energy,
and hyperscale
data centers.
Nichols received
his master’s
degree in urban
and regional
planning from
the University
of Iowa and has
been working
in the field of
planning for over
10 years. Outside
of work, he enjoys
tending to his
backyard chickens
and working on
home renovation
projects with his
wife and three
children.

Loudoun (Virginia), County of. 2025. Data Center
Standards & Locations.
Miet, Hannah. 2024. “Local Guidelines for Data
Center Development.” Washington, D.C.: Urban
Land Institute.
Miller, Rich. 2022. “The New MegaCampuses:
The World’s Largest Data Center Projects.”
Data Center Frontier, November 1.
Zoning Practice | American Planning Association | October 2025 11

Page 20 of 91

Morley, David. 2022. “Zoning for Data Centers and Cryptocurrency Mining.” Zoning Practice, June. American Planning
Association.
Morley, David. 2025. “Wait, Who Approves Large-Scale Solar
Siting?” APA Blog, March 3.
Morris, Jackson. 2024. “Data Centers Gobbling Up Existing
Nukes Threatens Grid Decarb Goals.” National Resources
Defense Council Expert Blog, July 11.
Pratt, Richard. 2025. “Cedar Rapids Council Approves Development Agreement for QTS Data Center Project.” Corridor
Business Journal, January 30.
Prince William (Virginia) Planning Office, County of. 2022.
DPA2021-0020: Data Center Opportunity Zone Overlay District Comprehensive Review.
Quincy (Washington), City of. 2025. Rate Resolution 25-709.
Riu, Isabelle, Dieter Smiley, Stephen Bessasparis, and Kushal
Patel. 2024. Load Growth Is Here to Stay, But Are Data Centers? San Francisco: Energy + Environmental Economics.

U.S. Energy Information Administration. 2024. Use of Energy
Explained: Electricity Use in Homes.
U.S. Environmental Protection Agency (USEPA). 2024. Greenhouse Gas Equivalencies Calculator.
Virginia Joint Legislative Audit and Review Commission
(VJLARC). 2024. Virginia Data Center Study: Electric Infrastructure and Customer Rate Impacts.
Van Geet, Otto, and David Sickinger. 2024. Best Practices for
Energy-Efficient Data Center Design. Washington, D.C.: U.S.
Department of Energy Federal Energy Management Program.
Walker, Willy. 2024. “The Future of Real Estate Is Digital: How
Data Centers and 5G Are Shaping the Next Generation of
Infrastructure.” Walker & Dunlop Market Trends, October 30.
Zhang, Mary. 2023. “Types of Data Centers: Enterprise,
Colocation, Hyperscale.” Dgtl Infra, November 26.
ZincFive. 2024. “Data Center Energy Storage Industry
Insights Report 2024.”

Ross, Brian, and Monika Vadali. 2024. “Battery Energy Storage Systems.” Zoning Practice, March.
RVA LLC. 2025. “The Underappreciated Need to Enable AI
and Data Center Growth.” Washington, DC: Fiber Broadband
Association.
Selsky, Andrew. 2022. “Oregon City Drops Fight to Keep
Google Water Use Private.” Associated Press, December 15.
Shehabi, Arman, Sarah J. Smith, Alex Hubbard, Alex Newkirk,
Nuoa Lei, Md Abu Bakar Siddik, Billie Holecek, Jonathan
Koomey, Eric Masanet, and Dale Sartor. 2024. 2024 United
States Data Center Energy Usage Report. Berkeley, CA:
Lawrence Berkeley National Laboratory.
Stansbury, Martin, Kelly Marchese, Kate Hardin, and Carolyn
Amon. 2025. “Can U.S. infrastructure Keep Up With the AI
economy?” Deloitte Insights, June 24.
U.S. Department of Energy, Secretary of Energy Advisory Board
(USDOE SEAB). 2024. “Recommendations on Powering Artificial Intelligence and Data Center Infrastructure.”

ZONING PRACTICE OCTOBER 2025 | VOL. 42, NO. 10. Zoning Practice (ISSN 1548–

American Planning Association
Creating Great Communities for All

0135) is a monthly publication of the American Planning Association. Joel Albizo, fasae, cae,
Chief Executive Officer; Petra Hurtado, phd, Chief Foresight and Knowledge Officer;
David Morley, aicp, Editor. Subscriptions are available for $65 (individuals) and $120
(organizations). ©2025 by the American Planning Association, 200 E. Randolph St., Suite 6900,
Chicago, IL 60601–6909; planning.org. All rights reserved. No part of this publication may be
reproduced or utilized in any form or by any means without permission in writing from APA.

Zoning Practice | American Planning Association | October 2025 12

Page 21 of 91

Local Guidelines
for Data Center
Development
By the ULI Americas Data Center Product Council

Page 22 of 91

© 2024 by the Urban Land Institute
2001 L Street, NW | Suite 200 | Washington, DC 20036-4948
All rights reserved. Reproduction or use of the whole or any part of the contents of this publication
without written permission of the copyright holder is prohibited.
Recommended bibliographic listing:
Urban Land Institute. “Local Guidelines for Data Center Development.” Washington, D.C.:
Urban Land Institute, 2024.

Page 23 of 91

About the Urban Land Institute
The Urban Land Institute is a global, member-driven organization comprising more than 48,000 real estate and
urban development professionals dedicated to advancing the Institute’s mission of shaping the future of the built
environment for transformative impact in communities worldwide. ULI’s interdisciplinary membership represents
all aspects of the industry, including developers, property owners, investors, architects, urban planners, public
officials, real estate brokers, appraisers, attorneys, engineers, financiers, and academics. Established in 1936, the
Institute has a presence in the Americas, Europe, and Asia Pacific regions, with members in 84 countries.
More information is available at uli.org. Follow ULI on X (formerly known as Twitter), Facebook, LinkedIn,
and Instagram.

Important notice and disclaimer
The content of this publication is provided for personal educational purposes only by the Urban Land Institute
(ULI) in furtherance of its tax-exempt mission, but it should not be relied upon as business or legal advice. The
content is provided on an “AS IS” basis without any warranties, express or implied. Additionally, the listing of
contacts at the end of this publication is for informational purposes only and does not constitute or imply any
endorsement of any company or individual by ULI.

Page 24 of 91

Project Team
Lead author
Hannah Miet,
President, Hannah Miet Consulting LLC

Urban Land Institute
ULI Americas Data Center Product Council

Page 25 of 91

LOCAL GUIDELINES FOR DATA CENTER DEVELOPMENT

Contents
1

2

3

4

5

6

7

Introduction: data centers 101

6

Essential infrastructure
Purpose and function
Types of data centers
Differences from industrial warehouses
Let’s tour a hyperscale data center campus
The importance of clustering

6
6
7
8
9
10

What happens when data centers come to your region:
opportunities, challenges, and mitigations

11

Opportunities
Challenges and mitigations

11
14

Long-term planning for data centers

18

Location considerations
Frequent missteps
Clear rules benefit all parties

18
19
19

Regulating data centers

20

Planning-related options

20

Model zoning ordinance guidelines

21

Zoning categories
Use standards for commercial areas
Use standards for industrial areas adjacent to residential
Parking requirements for all data centers

21
21
22
22

Appendix, contacts, and additional resources

23

Appendix: case studies
Contacts

23
25

Glossary

26

5

Page 26 of 91

1

Introduction: data centers 101

This paper seeks to demystify data centers and their purpose while offering
a balanced model zoning ordinance for data center development that
authorities having jurisdiction (AHJs) can adapt straight from the page.
It also aims to provide a roadmap to data center development for local
officials, planners, and other municipal decision-makers.
Data centers are still a relatively new land use, and they are often misunderstood or
miscategorized. To be ready when data centers are proposed in your jurisdiction or to attract
them, first it is important to understand their purpose in our society and how they function, as
well as to have strategies to mitigate common challenges.

Essential infrastructure
In the morning, most of us brush our teeth or take a shower. We
may not know where the water comes from or where it goes.
We may not know that it is treated at a plant and arrives at our
homes, where wastewater departs, is received in a facility, and is
released into surface water systems.
These days, we often check our email or social media first thing
in the morning, even before we shower or brush our teeth. The
internet—like water, sewer, and power systems—has become
part of our essential everyday infrastructure.

Water and sewage systems are typically financed and delivered
by local cities or counties. Power is funded and delivered by a
mix of public and private entities. Data centers, however, which
form the backbone of the internet, are financed, developed,
and operated primarily by privately held businesses. Unlike
what occurs with other critical infrastructure systems, the
development of data centers requires navigating a complex
landscape of private property laws, environmental impact
assessments, and local zoning regulations. Local officials, in
other words, play a key role in ensuring access to the internet
economy.

Purpose and function
A data center is a building that houses the infrastructure that
supports the world’s computing functions. This building is filled
with servers that process and store the data commonly referred
to as “the cloud.”

Processing and storage
Whenever you swipe your credit card, join a Zoom meeting, or

1. INTRODUCTION: DATA CENTERS 101

send an email, your virtual activity connects to a real place in the
physical world: a data center.
What gets processed in a data center? A better question: what
does not? Data centers house our national security systems,
including military communications. They enable online
commerce, financial services, health care, and other essential
services. Each app on your phone—even offline apps that
6

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LOCAL GUIDELINES FOR DATA CENTER DEVELOPMENT

sync—and every activity on the internet requires a data center.

Data centers’ primary function is processing and accessing data,
but they also store data, safeguarding sensitive information so
it’s inaccessible to hackers. When you save a file to the cloud,
you are not storing it in the sky. A data center stores it, more
efficiently and securely than a filing cabinet ever could.

When you use your smartphone, that tiny device does not
process your requests. Instead, your phone asks questions that
get answered in data centers—usually in a fraction of a second.1

Global data created annually in zettabytes
500

23% CAGR
2024-2030
375

250

125

2030E

2029E

2028E

2027E

2026E

2025E

2024

2023

2022

2021

2020

2019

2018

2017

2016

2015

2014

2013

2012

2011

2010

0

Source: JLL Research, IDC

The demand for more data center capacity
Our economy and communities were able to continue
functioning during the Covid-19 pandemic—when schools,
workplaces, and social gatherings shifted to the internet—
thanks in large part to the support provided by data centers.
This change also moved us further into an economy that exists,
largely, online.
The rise of remote work and advancements in artificial
intelligence (AI) that require high-density computing increased
the demand for processing and data storage, thus requiring

more data center capacity. As a result, this property category has
grown significantly.
If society and the economy continue the shift to the internet,
we would seem to face a need for more data centers. Where
these new data centers will be developed is a matter of great
importance that requires several variables to come together.
To discuss these variables, we first must discuss what a data
center is.

Types of data centers
Corporate or enterprise data centers, which store and
process a single organization’s data, rose in prominence in the
mid-1990s as the dot-com boom drove demand for fast internet
connectivity and 24/7 operations. These data centers often store

1

the data of financial institutions—think American Express or
Wells Fargo—that typically own and operate such facilities
themselves, rather than leasing them from a provider.

“One: You Use Data Centers,” Where the Internet Lives, Google, podcast audio, https://podcasts.apple.com/us/podcast/one-you-use-data centers/
id1541394865?i=1000501909698.
1. INTRODUCTION: DATA CENTERS 101

7

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LOCAL GUIDELINES FOR DATA CENTER DEVELOPMENT

At colocation data centers, which include retail data
centers, third-party operators lease data center space—a
certain number of server cabinets, for example, or kilowatts (kW)
to multiple companies.
Wholesale data centers are a type of colocation data center
where a third-party developer rents large portions of the space
and energy capacity to one company–often, all of it.
Telecom data centers, owned by telecommunications
companies such as Verizon, are where traffic from cell towers
“switches” to the internet. These facilities tend to be smaller than
the other data center types and require less energy.

Hyperscale data centers are built for a single customer: one
of the large tech companies that provide many of the services
we use every day—Google (Google Cloud), Amazon (AWS),
Microsoft, and Meta. These companies sometimes own their
own centers, and sometimes they lease them from a third-party
developer. These centers are built based on the data demands of
the hyperscaler.
The name hyperscaler emphasizes the ability to scale resources
up or down quickly and efficiently to meet demand. These
companies have a massive number of users and generate vast
amounts of data, which together demand substantial processing
power and storage capacity, especially as user bases grow
unpredictably.

Differences from industrial warehouses
Data centers differ from other forms of commercial real estate.
They constitute a relatively new category and, until recently, they
were concentrated in select geographic areas. As a result, the
buildings housing our essential internet infrastructure are widely
misunderstood.
Typically, data centers are not explicitly mentioned in zoning
codes. Instead, they fall under the umbrella of general industrial
zoning uses. But because they store data, they are not typical
warehouses. Their classification, as such, causes planning
challenges, which we will detail further in a later section.

1. INTRODUCTION: DATA CENTERS 101

Here’s how data centers differ from industrial warehouses or
factories:

•

Data centers are more compatible with other uses nearby
because, unlike factories or warehouses, they are odorless
and lack truck traffic.

•

They are often taller than traditional single-story
warehouses. Data centers can be single-story or multistory.
Single-story data centers start at around 30 feet (9.1 meters)
and multi-story data centers go up from there.

•

They require fewer employees once construction is
complete, so long-term impacts on traffic, schools, and
public services are minimal.

•

They need fewer parking spaces and plumbing fixture
counts than are typically mandated by industrial codes.

•

Data centers require more robust underground and aboveground infrastructure.

•

Unlike warehouses and factories, data centers have external
electrical and mechanical equipment.

•

Some data centers need multiple layers of redundancy,
which we’ll discuss in a moment.

•

Data centers require more security measures than industrial
buildings, including 24/7/365 surveillance and controlledaccess points.

8

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LOCAL GUIDELINES FOR DATA CENTER DEVELOPMENT

Let’s tour a hyperscale data center campus
EQUIPMENT
YARD (TYP)

ELECTRIC
SUBSTATION

SOUND WALL/
SCREEN WALL (TYP)

INCOMING
TRANSMISSION LINE

SECURE
PERIMETER FENCE

DATA HALL
(TYP)

GUARD
HOUSE

OFFICE

EMPLOYEE
PARKING
ACCESS ROADS AND FIRE LANES (TYP)

STORMWATER DETENTION POND

Most of the data centers developed today are hyperscale data
centers—typically within campuses. We tour one below.

Approaching the campus
As you approach a hyperscale data center campus, you are likely
to encounter a fence or gate—often with a gatehouse—beyond
which you may be able to see equipment yards and cooling
equipment in the distance.

Security
Data center campuses have extensive security measures
and strict protocols for employees and visitors. Infrared
surveillance cameras and tall, anti-climb security fences
that detect movement surround the property. A guard at the
gatehouse checks guests’ credentials outside. If you make it
past this point—few people do—you will find another security
checkpoint at the entrance to the data center building itself,
where additional security personnel check badges.

2

Equipment yards
Before heading inside, let’s first follow the winding campus
driveway and stop at the mechanical and electrical equipment
yards.
Electrical yards
In the electrical yards, you’ll hear the low hum of static if you
stand directly under the transmission lines. A nearby utility
substation transformer receives this power and converts it
down to the lower voltage needed for use inside. The mediumvoltage power feeds into switchgear in the electrical yard—or
another type of power distribution equipment that similarly
dispenses electrical power throughout the data center.
Alongside the switchgear, you will see multiple generators that
provide emergency power in case of an electrical utility outage.
If they look like they aren’t running, it’s because they are usually
turned off. Except during emergency outages, they are turned on
only for monthly maintenance tests for a mere 30 minutes2 and
are quiet while running due to sound-attenuated enclosures.

GeneratorSource, “Data Center Generator Maintenance,” GeneratorSource, January 2024, https://www.generatorsource.com/blog/January-2024/Data-CenterGenerator-Maintenance.aspx.
1. INTRODUCTION: DATA CENTERS 101

9

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LOCAL GUIDELINES FOR DATA CENTER DEVELOPMENT

Redundancy
Like hospitals, data centers require a high level of redundancy
to ensure they never go down, and the generators are part of
this preparedness. Redundancy is often also created through
multiple power feeds. The servers have backup capacity, too. For
instance, your inbox is stored on several servers so that if one
fails, your emails remain accessible.
Mechanical yards
The mechanical yards operate similarly but typically focus on
cooling rather than on power redundancy. On the ground, you’ll
find chillers that cool the data center. At some data centers, they
are on the roof.
Heat is a byproduct of computer processing. The servers within
data centers must remain cool to function correctly. There are
multiple ways of to achieve this cooling, but for the purposes
of this paper, we focus on three main categories: air-cooled
chillers, water-cooled chillers, and evaporative cooling.
A highly efficient air-cooled chiller system is sealed in a
closed loop and uses little to no water—less than the amount
used in three single-family homes.
Both water-cooled and evaporative systems use more water
and consume less electricity than air-cooled chiller systems. In
an open-loop water-cooled chiller system, cooling towers
evaporate water for cooling purposes. Evaporative cooling
is primarily achieved by large air-handling units that move air

across a wet medium to evaporate water, which removes heat
and cools the air in the data hall.

Data center structure
Let’s now make our way through the security checkpoint and
into the data center building itself. Inside, we find the data
hall, where the servers sit in rows of tall racks along a series of
aisles fed by electrical distribution equipment. Data halls
are the pièce de résistance of any data center. Such a structure is
typically designed from the data hall outward, with all supporting
infrastructure responding directly to its needs.
If you examine the racks from the floor upward, you see bundles
of colorful fiber optic cables (inside of which are thin strands
of glass) connecting servers to switches and routers. These
cables enable high-speed data transfer. Without them, we would
be unable to access the web or many of the apps we use daily.
The cables are organized in lanes that converge at massive
switches.
Inside the data center building, you also find electrical rooms
that house other critical power supply infrastructure. Batterypowered uninterruptible power supply (UPS) systems sit in
large cabinets against the wall. In the event of a utility outage,
these systems feed power to power distribution units (PDUs)
inside the data hall. UPS systems are the first-used backup
power source and often prevent use of the generators outside.

The importance of clustering
The internet is a network of interconnected networks, and so
are data centers. Clustering refers to the practice of linking the
servers at multiple data centers with high-speed, low-latency
connections so they work together as a unified system. This
interconnected group is called a cluster, and each server in the
cluster is called a node.
Importantly, clustering requires physical proximity: locating
multiple data centers close to one another geographically so that
optical signals in fiber cables don’t lose strength. That’s why a
huge portion of global internet traffic passes through major hubs
such as northern Virginia’s “Data Center Alley.”
Clustering also requires interconnection—linking these data
centers through high-speed, low-latency connections.

Reduced latency
One primary reason for data center clustering is to reduce
latency, the time it takes for information to travel from its
source to its destination. When data centers are geographically
distant from each other, latency increases, which leads to
slower application performance for end users, including the
dreaded “spinning wheel of death.” When data centers are
1. INTRODUCTION: DATA CENTERS 101

located near each other, data can travel shorter distances, and
this information exchange runs faster. Due to quicker response
times, the user experience improves.

Improved reliability
Clustering enhances redundancy. If one data center server goes
offline, others in the cluster can take over, ensuring continuous
service availability. Without clusters, one server failure could
cause an outage with international implications. In the appendix,
we explore this concept further through a case study.

Load balancing
Clustered data centers allow for more efficient load balancing,
the process of distributing network traffic across multiple servers
at interconnected data centers. This practice prevents any single
server or center from becoming overwhelmed.

Shared infrastructure
Data centers require conduits for power and, in some cases,
water. When data centers cluster, they benefit from shared power
and cooling infrastructure while also reducing the need for longdistance fiber optic connections.
10

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2

What happens when data
centers come to your region:
opportunities, challenges,
and mitigations
Opportunities

Data centers can provide significant
economic benefits and other opportunities.
Data center projects also introduce unique
planning challenges, however. To be
prepared, and to seize opportunities when
appropriate, AHJs must understand these
challenges and how to mitigate them.

Support essential national infrastructure
Data centers contribute to national infrastructure and economic
growth. Also, they enable the digital economy by underpinning
businesses of all sizes in virtually every industry.
According to the United States Department of Energy3,“At
a national level, data centers are critical to supporting
America’s economic growth by powering businesses and
enabling continued leadership in innovation, including for AI
applications.”

HERE’S HOW DATA CENTERS SUPPORT NATIONAL SECURITY AND ECONOMIC GROWTH:
They protect the privacy of all of the data within U.S.
borders against cyber threats by powering security
measures such as encryption, firewalls, and access
controls.

Data centers also support the development and
deployment of emerging tech. Data centers are the
backbone of AI infrastructure, which requires rapid
data processing, storage, and analysis at scale.

They host critical infrastructure for our emergency
services, providing the necessary computing power
and data storage to support communication networks,
emergency response coordination, and real-time data
analysis during crises.

On a macroscale, maintaining advanced data center
infrastructure allows the U.S. to compete with such
countries as China in the race for AI dominance, thus
fostering economic growth and strengthening national
security through technological leadership.

Our health care system depends on data centers. They
enable a range of services, from telehealth visits to
managing digital health records, and they even assist
in providing data-analysis-informed diagnoses for
patients.

On a microscale, data centers also improve
businesses’ operational efficiency by democratizing
access to supercomputer processing and secure cloud
storage so that small businesses can compete more
easily with larger corporations.

Banks and the rest of our financial ecosystem rely on
data centers for their daily operations.

3

U.S. Department of Energy, “Clean Energy Resources to Meet Data Center Electricity Demand,” https://www.energy.gov/policy/articles/clean-energy-resourcesmeet-data center-electricity-demand.
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Increase much-needed processing and storage capacity

Growing global data center demand in gigawatts
83.6

90

~2.5x
Growth

75

60

~2x

45

30

34.0

Growth

17.5

15

0
2019

2020

2021

2022

2023

2024E

2025E

2026E

2027E

2028E

Source: CBRE, DC Bytes

Our needs for data center capacity have grown—and continue to
grow at a fast clip as we create more data.
If we don’t build data centers that support this increasing data
density, it could hamper the economy, business operations, and
our daily lives.
On a microlevel, a lack of data center capacity or redundancy
makes files and apps load slowly. On a macrolevel, if we don’t
build enough data centers to meet our growing storage and
processing needs, there will be outages with international
consequences, like the October 2021 Meta outage. We include
a case study on this incident and its profound impacts in
the appendix.

Jobs

phases can extend over several years. This phased approach
often leads to misunderstandings regarding the permanency of
the increased traffic. Clear communication about the nature and
duration of construction phases can help manage expectations
and reduce misunderstandings.
This phasing approach has a plus side, however. Data centers
create local construction jobs for tradespeople who otherwise
travel from job to job—with less fossil fuel consumption thanks
to reduced commuting. Jobs related to data center construction
typically provide these workers, sometimes called journeypeople, with more stability and longer timelines, offering a
higher quality of life. This outcome, in turn, can prevent or
alleviate labor shortages and reduce renovation and building
expenses in the area, benefiting homeowners and businesses.

When data centers are in operation, they require fewer
employees to operate than most other commercial properties,
leaving minimal impacts on traffic in surrounding areas. A
typical data center operates with fewer employees than other
commercial or industrial facilities. Unlike industrial facilities,
there is no fleet of trucks going in and out, which further
minimizes traffic congestion.

Although the operational workforce of data centers is relatively
small, people employed in these roles are well-compensated,
often earning six-figure salaries without the need for significant
training or a college degree. During both the construction and
operational phases, data center jobs boost to the local economy
because workers spend at retail stores, nearby restaurants,
hotels, and suppliers.

More workers are present while the data center campus is under
construction, though. Data center construction projects happen
in phases, especially on larger campus developments, and these

Data centers also indirectly create many jobs across the broader
economy. According to PricewaterhouseCoopers International
Limited4 (PwC), each direct job in the U.S. data center industry

4

PwC, “Economic Impact Study of the US Data Center Industry,” January 2021; “Data Centers and Ancillary Job Creation,” TechIndustryReview, March 2022.
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generates, on average, six ancillary jobs throughout the national
economy. As a result, the total annual impact of the data center
industry on national employment—combining direct, indirect,
and induced effects from both construction and operations—
grew from 2.9 million jobs in 2017 to 3.5 million jobs in 2021,
representing a 20 percent increase.
Furthermore, the PwC study does not include jobs created
by the cloud access and processing power that data centers
enable. Data centers also facilitate zero-commute remote work
across the country, further reducing fossil fuel consumption and
contributing to a more sustainable economic model.

Tax revenue
Data centers provide municipalities with substantial economic
and fiscal benefits through various forms of tax revenue (if
unabated) that far exceed ones associated with other property
types.
Hyperscale data centers are capital-intensive developments that
can cost billions to construct—and are filled with high-value
equipment and infrastructure. Taxes levied against them can be a
windfall for AHJs.
A case in point: the data center tax base in Loudoun County, the
central hub of North Virginia’s Data Center Alley, increased from
$15.996 billion in 2023 to $25.627 billion in 2024, constituting
58.5 percent of the municipality’s total tax revenue.5
Data center owners pay two primary forms of property taxes. The
first is real property tax, which applies to the land campuses are
built on and the permanent structures that sit upon it, such as
buildings. The second is personal property tax, which is levied
on movable assets such as the servers and equipment inside
data centers.
These revenues become significant boons to surrounding
municipalities. In Loudoun, personal property tax revenue from
computer equipment purchases for data centers surged by 170
percent in 2023, accounting for two and a half times the tax
revenue.
The presence of data centers can also lower the overall tax
burden for residents. In Loudoun, the general property tax rate

is set at $0.87 per $100 of assessed value; it would be $1.33
(an additional 52 percent) but for the influx of data center
developments, according to the county’s executive director of
economic development.6 Revenue from data centers accounts
for $0.47 of the tax rate, thereby alleviating the burden on other
taxpayers.

Data center revenue can be channeled into
net-zero programs and those related to health
care, education, and other critical public services.
Data center revenue can be channeled into net zero programs
and ones related to health care, education, and other critical
public services. Revenue from data centers in Quincy,
Washington, for example, has been used to fund local schools,
public safety, and infrastructure improvements.7
By 2026, Loudoun County projects it will receive roughly
$1.4 billion in tax revenue from the personal property tax it
levies on computer equipment alone.8 This amount constitutes
nearly half of Loudoun County’s entire fiscal 2021 budget of
$3 billion.

Community incentive packages
Data center operators also provide significant benefits through
incentive packages negotiated with municipalities that can
include funding for schools or public infrastructure projects.
In multiple cases, hyperscalers have funded renewable energy
plants and created workforce development programs in areas
where they operate.
As part of AWS’ $10 billion data center campus investment in
Mississippi, the company developed STEM-focused workforce
training and career awareness programs for K-12 school
systems and funded the state’s first utility-scale wind farm.9 You
can learn more about the community benefits the hyperscaler
provided in the appendix.

5

Emily Leayman, “Loudoun’s Data Center Tax Base Jumps, Residential Increases Continue,” Patch, February 8, 2024, https://patch.com/virginia/ashburn/
loudouns-data-center-tax-base-jumps-residential-increases-continue.

6

Hanna Pampaloni, “Rizer: Land Value Increases Bring Benefits and Challenges,” Loudoun Now, June 28, 2024, https://www.loudounnow.com/business/rizerland-value-increases-bring-benefits-and-challenges/article_5b417aa8-3592-11ef-b587-f7ca7fd349c0.html.

7

Nick Parker, “Quincy Data Centers: The Data Center Conversation” (Presentation, Port of Quincy), https://wedaonline.org/wp-content/uploads/2020/10/Port-ofQuincy-Presentation.pdf.

8

“Loudoun Data Center Revenue Growth,” Washington Business Journal, October 19, 2020, https://www.bizjournals.com/washington/news/2020/10/19/loudoundata-center-revenue-growth.html.

9

Amazon Staff, “AWS plans to invest $10 billion in Mississippi, the largest capital investment in the state’s history,” About Amazon, January 25, 2024, https://www.
aboutamazon.com/news/aws/aws-10-billion-investment-mississippi.
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The region that includes Fredericksburg, Virginia—an emerging
exurban hyperscale campus market located southeast of
Loudoun County—is a case study in how AHJs can attract
landslide economic and fiscal benefits while mitigating potential
concerns well in advance.
In March 2024 Virginia’s governor, Glenn Youngkin, alongside
other state and local elected officials, announced that AWS
was making a $35 billion dollar investment in data centers in

Spotsylvania, Caroline, Stafford, and Louisa counties, creating
approximately 2,000 new jobs. Also announced was AWS’
contribution of $400,000 in community funds to those localities.
We explore how AHJs in the region did the work to prepare
for and attract that investment in the appendix, which also
covers similar measures in Elk Grove Village, Illinois, a unique
suburban community northwest of downtown Chicago that
modified its zoning code to attract data center development.

Challenges and mitigations
Sustainability
The sustainability of data centers is a significant concern for
both AHJs, as well as for data center operators and developers,
who ensure that their centers are designed and engineered to
minimize emissions and other community impacts.
Grid impact
Let’s address the misconception that data centers draw from the
grid power that other customers, such as residential consumers
and retail operators, could use. This concern is common among
constituents when a data center is proposed in a municipality.
The grid is heavily regulated. Under existing federal regulations
(and in Texas, the only state that regulates its own power grid),
demand from a new customer cannot affect the reliability or
availability of an existing customer.
Rather than taking power from the grid, new large-load
customers such as data center operators face the challenge of
finding readily available power that the utility can deliver—
especially because many seek clean power sources.
According to the U.S. Department of Energy (DOE), as quoted
in a recent article,10 data centers can actually catalyze the grid’s
clean energy transition: “Near-term data center driven electricity
demand growth is an opportunity to accelerate the build-out
of clean energy solutions, improve demand flexibility, and
modernize the grid while maintaining affordability.”
Here’s why: in many municipalities, energy providers are
obligated to meet the power demands of various users. When a
significant portion of demand comes from data center operators,
many of which have strong commitments to using renewable
energy, that activity accelerates the greening of the grid. These
companies, driven by their climate goals, place considerable
pressure on utility providers to adopt cleaner energy solutions.

10

“Near-term data center driven electricity demand
growth is an opportunity to accelerate the
build-out of clean energy solutions, improve
demand flexibility, and modernize the grid while
maintaining affordability.”
U.S. Department of Energy

Unlike AHJs, which cannot create the demand to push
forward such changes themselves, data center operators wield
considerable influence by creating substantial demand for
renewable energy.
This dynamic forces utilities to accelerate and help finance
their transition to greener energy sources, thereby modernizing
the grid to meet contemporary environmental standards.
Public officials have a critical role to play in this scenario. By
ensuring the existence of clear and easy-to-follow guidelines
for data center development within their jurisdictions, AHJs can
become integral to the solution, thus fostering a cleaner energy
infrastructure.
Conversely, discouraging data center development could
inadvertently push these operations into regions with less
stringent grid standards and undermine broader sustainability
efforts. Thus, the collaboration between data center operators
and local governments is pivotal in driving the clean energy
transition and ensuring grid modernization.

U.S. Department of Energy, “Clean Energy Resources.”

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Grid sustainability
Data center companies—third-party developers, operators, and
hyperscalers among them—typically have far stricter carbon
reduction commitments than do municipalities themselves.
•

The top five hyperscalers have a combined renewable
energy portfolio totaling more than 45 gigawatts (GW)
worldwide, the equivalent of roughly 118,215 Tesla Model
3 motors11 running on full power—and that figure doesn’t
include on-site generation.12 Roughly 57 percent of global
corporate wind and solar capacity tracked by S&P Global
Commodity Insights is tied to these five companies alone.

•

Amazon first committed to powering all of its operations,
including AWS data centers, with 100 percent renewable
energy by 2025. As of 2023, Amazon reported achieving
this goal early, with 100 percent of its electricity
consumption matched with renewable energy sources. The
company also set a goal to reach net-zero emissions by
2040.13

•

Microsoft committed to designing and operating data
centers that are carbon negative, water positive, and zero
waste before 2030, procuring 100 percent renewable energy
on a global scale by 2025, and significantly expanding and
decarbonizing local electricity grids.14

•

Apple has committed to becoming carbon-neutral across
its entire supply chain and product life cycle by 2030. This
effort includes using nearly 10 GW of existing renewable
energy and investing in new renewable generation.15

•

Google, meanwhile, announced its goal in September 2020
to operate carbon-free, on clean local electricity, 24 hours
a day, 7 days a week, 365 days a year by 2030. From 2010
to 2023, the company signed more than 115 agreements
totaling in excess of 14 GW of clean energy generation
capacity.16

•

Meta committed to net zero emissions for its supply chain
and to becoming water positive by 2030. The company
plans to power all of its data centers with renewable energy
by 2025.17

The methods through which hyperscalers and data center
developers are working toward these goals include:
On-site generation: Some data centers have solar panels
or other renewable energy sources installed directly on their
premises. Wind and solar require a lot of land, however, and
on-site land is usually scarce. As such, these projects typically
provide only a small portion of data centers’ total energy needs.
Power purchase agreements (PPAs): In a PPA, data
center companies (the buyers) sign long-term contracts with
renewable energy providers (the sellers) to purchase electricity
from specific wind or solar farms. PPAs often support the
development of new renewable energy, thus contributing to
overall grid decarbonization and improving the grid mix for local
residents and businesses.
Renewable energy certificates (RECs): Companies purchase
RECs to offset their energy consumption, which supports
the economics of clean energy development. RECs are not
necessarily tied to the specific municipalities where data centers
are located, though.
Investment in renewable projects: Hyperscalers often invest
directly in the development of new renewable energy projects.
Diesel generators
The role of diesel generators at data centers is often
misunderstood. As we discussed elsewhere, these generators
are present only as a backup power source.
Also worth noting is that diesel generators are subject to a
comprehensive regulatory framework. The Environmental
Protection Agency (EPA) sets federal standards implemented
and enforced at the state level for generators, and states may

11

U.S. Department of Energy, “How Much Power is 1 Gigawatt?” Office of Energy Efficiency & Renewable Energy, https://www.energy.gov/eere/articles/how-muchpower-1-gigawatt.

12

S&P Global Market Intelligence, “Datacenter Companies Continue Renewable Buying Spree, Surpassing 40 GW in US,” S&P Global, https://www.spglobal.com/
market-intelligence/en/news-insights/research/datacenter-companies-continue-renewable-buying-spree-surpassing-40-gw-in-us.

13

Amazon, “Climate Solutions,” Amazon Sustainability, https://sustainability.aboutamazon.com/climate-solutions.

14

Microsoft, “Microsoft’s Datacenter Community Pledge: To Build and Operate Digital Infrastructure That Addresses Societal Challenges and Creates Benefits for
Communities,” Microsoft Blog, accessed September 15, 2024, https://blogs.microsoft.com/blog/2024/06/02/microsofts-datacenter-community-pledge-to-buildand-operate-digital-infrastructure-that-addresses-societal-challenges-and-creates-benefits-for-communities/.

15

Apple Inc., “Apple’s Climate Roadmap,” Apple Newsroom, https://www.apple.com/newsroom/2021/07/apples-climate-roadmap/.

16

Google, “Build a Carbon-Free Future for Everyone,” Google Sustainability, accessed September 15, 2024, https://sustainability.google/projects/carbon-free24x7/.

17

Meta, “The Next Stage of our Climate Commitment: Net-Zero Supply Chain Emissions by 2030,” Facebook Newsroom, https://about.fb.com/news/2021/10/thenext-stage-of-our-climate-commitment-net-zero-supply-chain-emissions-by-2030/.

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have additional requirements.18 Once permitted, each diesel
generator’s operation is bound by strict regulations. Operators
typically may run generators for only a limited number of hours
per year for routine maintenance and inspection purposes.
Although it varies by facility, generators at data centers are
typically used far less than these rules dictate. Generators’ brief
monthly operation to ensure proper functioning is comparable
to running a pump system that’s been inactive for an extended
period—regular checks prevent potential issues that accompany
prolonged inactivity, such as seized components or degraded
lubricants.
Greener alternatives to diesel are in various stages of
development, but none has been proved at scale yet.
Water sustainability
Cooling accounts for almost 40 percent of the total energy
consumed by data centers, McKinsey and Company estimates.19
Several factors determine the type of cooling that is most
sustainable yet still suitable for the job.
Air cooling can be more efficient at lower load percentages
and smaller equipment capacities. It can also be sustainable at
any scale when the data center is located in an area with a high
percentage of renewable sources in the energy grid, including
ones generated on site.
When cooling processes require water, nonpotable water
sources can be used so as not to reduce the local drinking water
supply. Nonpotable water is treated—either at a local plant or,
in some cases, on site–to remove contaminants, solids, and
impurities. Then recycled water is then distributed in plumcolored pipes, which accounts for the nickname the purple
pipe system. To pursue it, companies often consider access to
recycled wastewater an important factor in the early stages of site
selection.
Hyperscalers have even helped AHJs finance such projects,
though that’s not always viable, which makes proximity to
existing treatment facilities a key consideration. In 2012, Google
funded the construction of the Sweetwater Creek Sidestream
Plant in Douglas County, Georgia, which we explore further in
the appendix.

Electrical utility transmission and distribution
When developers vet a site for a data center, they consider
whether there are adequate transmission lines. At the local level,
there can be pushback against the building of new transmission
lines, inside and outside a data center context. Local pushback
against transmission lines increased by 57 percent from 2022 to
2023, according to Columbia Law School research.20
This challenge exists not just for data centers but also for the
clean energy transition. One truism says that the transition can’t
happen without transmission. Here’s why: as more sectors such
as transportation go electric, overall power demand is likely to
increase, requiring greater transmission capacity. Grids in the
U.S. are not connected, which is a problem because such clean
energy sources as solar and wind are often located far from
urban centers, where electricity is most needed. Connecting
grids across the country requires a plethora of new transmission
lines.
“By the 2030s, we need to build so many new lines that they
would reach to the moon if they were strung together,” says
Bill Gates, cofounder of Microsoft, in a video on his YouTube
channel. “And by 2050, we’ll need to more than double the size
of the grid, while replacing most of the existing wires.”
Most transmission lines, built between the 1950s and the 1970s,
are now outdated.21
How did we get here? For a long time, electricity generation
was centralized, and there was no need for a connected grid.
Large coal-powered plants and nuclear power plants produced
massive amounts of electricity in specific locations. This
electricity was then distributed widely to homes, businesses, and
industries throughout a large area. Power flowed primarily in
one direction: from centralized plants to distributed end users.
As we transition to clean grid sources, however, we need a less
centralized, more distributed system. Unlike fossil fuel plants,
renewable energy sources are often geographically dispersed,
variable in output, and located far from major consumption
centers. They require a shift to an interconnected grid with
diverse, distributed sources, one that’s more resilient to outages
and increasingly frequent extreme weather events caused
by climate change. This shift requires more cross-regional
transmission or inter-regional transmission. It requires . . .
transmission lines.

18

U.S. Environmental Protection Agency, “Regulations for Emissions from Heavy Equipment with Compression-Ignition Engines,” https://www.epa.gov/regulationsemissions-vehicles-and-engines/regulations-emissions-heavy-equipment-compression.

19

Srini Bangalore et al., “Investing in the Rising Data Center Economy,” McKinsey & Company, January 17, 2023, https://www.mckinsey.com/industries/
technology-media-and-telecommunications/our-insights/investing-in-the-rising-data center-economy.

20

“Opposition to Renewable Energy Facilities in the United States,” Sabin Center for Climate Change Law, Columbia Law School, May 2023, https://scholarship.
law.columbia.edu/sabin_climate_change/200/.

21

Bill Gates, “The Surprising Key to a Clean Energy Future,” Gates Notes, January 24, 2023, https://www.gatesnotes.com/Transmission.

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Often, constituents don’t understand that transmission lines are
an essential part of our sustainable future, even without data
center demand. Properly communicating this message to a
community isn’t easy, but it’s essential. Siting data centers near
transmission infrastructure is most efficient, as doing so allows
for use of the existing infrastructure and the associated rights of
way for new infrastructure, if needed.

Aesthetics
Community members often raise concerns about whether data
center campuses will look as if they fit into the community. This
issue can be mitigated by:

•

Creating buffer zones near residential and retail areas

•

Employing glass façades in key areas to make data centers
more closely resemble office buildings than industrial
complexes

•

Applying other exterior design techniques that use materials
and colors to blend buildings into their surroundings, if
required and appropriate to the context

Sound
Another common community concern is sound. Most
mitigations related to it are already baked into the development
process. Data center designers, architects, and engineers
tend to design data center campuses to mitigate impacts from
sound upon nearby neighbors, including strategic placement of
generators away from other uses. Developers typically employ
on-site acoustic monitors as part of regulatory entitlements to
ensure sound levels remain within acceptable limits.
Let’s discuss where sounds occur at data center campuses.
Remember the low hum in the equipment yards? It comes from
cooling equipment. Screens and sound attenuators make it
barely audible.
Generators make mechanical sounds, albeit only when they are
turned on for testing or emergencies. Sound impacts can also
be easily mitigated by housing generators in sound-attenuated
enclosures with proper exhaust systems.

Although these mitigations are effective, it’s important not
to codify excessively specific or restrictive design standards
into zoning codes, as doing so can discourage data center
development. Exceedingly stringent height restrictions, for
example, could hinder the functional design of these facilities.
Balancing aesthetic considerations with operational needs of
data centers is key.
More important than any one mitigation is effective community
education. Many residents do not understand the purpose and
benefits of data centers, which have been outlined herein, such
as how they support daily internet activities and contribute to
local tax revenues.

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3

Long-term planning
for data centers

Location considerations
Because of their unique operational and physical requirements, several crucial
factors must be considered when deciding what sites suit data centers:
Power

Data centers are power-intensive.
Reliable and robust access to power is
non-negotiable, making proximity to
high-capacity substations essential.

Whereas operational traffic is minimal,
the initial construction phase generates
more traffic. Thus, easy access to
highways and major roads is vital for
logistics and transportation.

Discharge infrastructure

If there is runoff from water-based cooling, a site will need
adequate infrastructure for wastewater discharge, such as a
connection to a municipal sewer system, an on-site water
treatment facility, or proper drainage.

3. LONG-TERM PLANNING FOR DATA CENTERS

Land

Roads

Hyperscale campuses require ample
land area to accommodate both
the facility and its accompanying
infrastructure.

Wet utilities

Some data centers require access to municipal water supply
greater than what typical industrial developments need. The
climate goals of most hyperscalers and developers are driving
demand for recycled, rather than potable, water.

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Frequent missteps
Common pitfalls in planning for data centers include:
Height restrictions:
Failing to allow sufficient building height can impede the efficient
design of cooling systems, which rely heavily on vertical space for
optimal airflow. The minimum height for a single-story data center
could be as much as 30 feet (9.1 m). In denser jurisdictions
with higher land basis, multistory data centers are common and
typically require at least 66 feet (20.1 m) of height, in addition
to considerations for rooftop equipment. Minimum heights are
generally measured ground level to the roof line. Ancillary height
structures, such as parapets, equipment platforms, screens, and
stairwells can add another 15–20 feet (4.6–6.1 m) of height in
some cases.

Building code challenges:
Typical building code requirements around occupancy and
plumbing fixtures may need to be modified for data center uses.

Substation zoning:
Substations often fall under different categories than does the
data center itself, creating further zoning inconsistencies and
the need for additional, sometimes separate, approvals for one
campus.

Zoning challenges:
The lack of a uniform land-use category for data centers
presents challenges for localities in siting these facilities
appropriately. Data centers typically fall between office and
industrial/warehouse uses, which often makes the applicant
request variances that appear to be special considerations rather
than basic requirements. This outset can lead to high-stakes
decision-making by exception that undermines the existing
zoning codes.

Parking and plumbing standards:
Regulations developed for office or warehouse uses often
impose excessive parking and plumbing fixture counts on
data centers, which necessitate variances and complicate the
planning process.

Construction confusion:
Data center campuses are often built over time, as we discussed
above, which can cause planning confusion. The sightlines of a
campus may change over time, so it’s important to consider both
the full campus and each individual building in the planning
process.

Fire Department considerations:
Fire departments that are not yet experienced with data centers might not know that the on-site batteries and generators are for backup
purposes only, so education is essential. Yet even though those backups aren’t frequently used, data centers are built with robust
fire detection and suppression systems. Modern batteries for UPS applications include multiple safety features, including battery
management systems that monitor voltage, temperature, and current. Fuel tanks for backup generators are typically stored in separate,
fire-rated enclosures, and secondary containment systems are used to prevent fuel spills and leaks.

Clear rules benefit all parties
Clear rules in zoning codes and land use plans, as well as in the
entitlement and permitting processes, benefit all stakeholders
involved in data center development, including the surrounding
community.
Clarity simplifies the planning process, reduces the amount of
planning that is done by exception, and lets communities gain
maximum financial benefits from data center developments.
3. LONG-TERM PLANNING FOR DATA CENTERS

In the next few sections, we discuss planning options for
AHJs seeking to be prepared to regulate thoughtful data center
development, to attract it, or both. We also provide a model
zoning ordinance that municipalities can adopt, designed to
address common concerns while avoiding excessively restrictive
measures that could hinder data center development.

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4

Regulating data centers

Planning-related options
AHJs that want to bring data centers to their region can start by
identifying strategic locations. Municipalities should perform
comprehensive analyses to determine suitable areas, based on
power availability, infrastructure, and environmental impact.

Option 1: Create an overlay district
One option for guiding the development of data centers is to
incorporate an overlay district. An overlay district is mapped to
certain areas of the jurisdiction’s zoning map without necessarily
changing the underlying zoning district and what is allowed
therein.
A historic overlay district is a common application of this
tool. It typically provides for certain additional standards—an
expansion of the uses that might be permitted in that district, a
limitation of them, or some mix of the two.
A data center overlay district can allow for the development of
data centers and prescribe that such development meet certain
standards or requirements. An overlay district clearly indicates
where and under what circumstances data centers are permitted
and provides additional direction to any data center developer
seeking to develop in that jurisdiction.

Option 3: Note preferred data center locations
in the comprehensive plan and invite owner- or
hyperscaler-initiated rezoning applications
AHJs can identify preferred locations for data center
development in their comprehensive plans and invite rezoning
applications in those areas.
Municipalities and data center companies can agree on
development conditions—sometimes called proffers,
development agreements, or conditional zoning—which are
voluntary commitments made by developers in return for
allowed zoning. They outline specific conditions or promises
agreed upon to mitigate the impact of proposed developments or
to otherwise benefit the municipality’s residents.
Development conditions may include infrastructure
improvements, restrictions on use, environmental protections,
community benefits, and other strictures. They are flexible
enough to apply to various zoning categories, including PIRTs.

22

Ideally, more than one area should be designated for potential
development—as with the process for industrial parks—to
provide flexibility and attract varied investments.

Option 2: Create a planned innovation,
research, and technology (PIRT) district
PIRTs—and their regional equivalents, which include innovation
zones, technology corridors, and research and technology
parks—offer municipalities a flexible approach to land use that
goes beyond traditional industrial or commercial zoning.
This designation allows for a mix of uses and can adapt to the
specific requirements of data centers without necessitating a
rezoning. Data centers in a PIRT district can integrate seamlessly
with adjacent research facilities or tech hubs, fostering
synergistic growth and innovation. Examples of successful PIRT
districts include Palo Alto’s Stanford Research Park.22
When data centers are sited clearly as being a by-right use,
data center developers are more likely to consider the location
for investment because they have the required certainty that the
land they acquire won’t struggle or be delayed in the approvals
process. In the appendix, we explore how Elk Grove Village did
so successfully.

Option 4: Implement a specific data center
zoning district defined by ordinance
Creating a data center-specific zoning district is a solution
that’s more detailed and restrictive than the previous three. We
recommend it as a best practice in many jurisdictions because it
establishes clear guidance on where data centers are permitted
by right and eliminates the possibility that high-stakes decisions
are made by exception. The ordinance should define data
centers and outline general standards for building them, such as
building size thresholds, height limits, and floor area ratio (FAR)
requirements.
The zoning ordinance should include specific use standards for
data centers, such as parking, setbacks, buffering, plumbing
fixture counts, equipment screening requirements, and
operational sound limits. The next chapter consists of a model
ordinance that AHJs can adopt.

“About Stanford Research Park,” Stanford Research Park, https://stanfordresearchpark.com/about/.

4. REGULATING DATA CENTERS

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5

Model zoning ordinance
guidelines

AHJs that want balanced and transparent zoning standards that
mitigate unwanted impacts while encouraging the many potential
benefits of data center development can take this zoning
ordinance off the page and adapt it.
No two jurisdictions are the same. Each needs to layer in its own
considerations.

Our intention, however, is to offer a strong foundation upon
which AHJs can build zoning districts for data centers defined
by ordinance. Note that the language provided below is to
be included in the zoning ordinance and there may be other
provisions that govern development, such as in the building
code as it pertains to plumbing fixtures, that may need to be
adjusted.

For example:
•

Rural counties can consider additional guidelines and
requirements when a data center is adjacent to certain
agricultural uses or other sensitive uses.

Zoning categories
Broadly, zoning districts in which data centers have specific
considerations fall into four categories:
Residential: Because data centers are ultimately an industrial
use, we believe that data centers are not appropriate in
residential districts.
Industrial: Given the nature of data centers, they should be
permitted in all industrial categories, from light industrial
to heavier industrial. In such areas, data centers should be
permitted as any other industrial use would be allowed,
including following the same height, setback and landscaping
requirements.
Rural/agricultural: In rural areas, data centers should be
permitted to the extent that industrial uses would be permitted
in such areas, provided that the same conditions are applied
that would be applied to permissible industrial uses on such
land. If another industrial use would require a certain setback,
landscaping treatment or other mitigation on rural or agricultural
land, our recommendation is that the same conditions be
applied for a data center on such land.
Commercial: Data centers in commercial areas can be
appropriate, provided they comply with certain use standards
as set forth below. For the purpose of this section, commercial
districts are defined as ones that permit a diversity of
nonresidential uses, such as office and retail.

5. MODEL ZONING ORDINANCE GUIDELINES

•

Urban municipalities can consider additional guidelines and
requirements when a data center is adjacent to transit hubs
or to prioritize pedestrian activity.

Use standards
for commercial areas
Data centers shall be permitted by right in commercial districts if
the following criteria are met:
1. To provide screening and reduce noise levels, all equipment
for cooling, ventilation, or otherwise operating the facility—
including generators or other power supply equipment—
must be fully enclosed, except when determined by the
[zoning administrator] not to be mechanically feasible. If the
zoning administrator determines that full enclosure is not
mechanically feasible, all equipment for cooling, ventilation,
or power generation must be screened by a wall or similar
barrier. In addition, any accessory electrical substation
must be screened from adjacent nonindustrial properties
or public streets by a wall or similar barrier. This standard
does not apply to solar panels.
2. A data center building must include a main entrance feature
that is differentiated from the remainder of the building
façade by a change in building material, pattern, texture,
color, or accent material. The entrance feature must also
either project or recess from the adjoining building plane.
3.

The primary façades of data centers must include either:
a.

A change in the primary facade surface for every
approximately 150 horizontal feet of at least one of the
following: building material, pattern, texture, color, or
accent material; or

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b. A minimum of thirty percent (30%) of the primary
facade shall be comprised of windows, doors, or
similar fenestration design features such as faux
windows that are generally distributed horizontally and
vertically across the façade.
c.

These standards do not apply to accessory uses.

d. For the purposes of this requirement, a primary facade
shall be deemed to be a facade that fronts on a public
street.
4. Buildings may be constructed up to one hundred (100)
feet (30.5 meters) in height or taller with special exception
approval and subject to FAA limitations.
5. FAR shall not exceed [1.5 times the maximum FAR of
the commercial district] without approval of a special
exception. With approval of a special exception, the FAR
may be increased to [2.5 times the maximum FAR of the
commercial district].

Parking requirements
for all data centers
As referenced elsewhere in this document, the parking
requirements for data centers are far less than would be required
for another industrial or commercial use of a similar size.
Overbuilding parking for a given data center site or campus can
be unnecessarily costly but more importantly creates excess
impervious surface and avoidable environmental consequences.
Accordingly, we recommend that the parking requirements for
data centers be established either by:
1. Applying the parking requirements for office that exist in the
ordinance, but only to the portion of the data center building
that is actually utilized for office space; or
2. Requesting a staffing plan from the data center developer
and allowing such data to inform the minimum number of
needed parking spaces.

Use standards for industrial areas
adjacent to residential
Although data centers are appropriate in all industrial zoning
categories, special attention may be afforded when industrial
land is adjacent to residential. In such cases, the following
language could be included in the locality’s zoning ordinance:
1. Where industrial is adjacent to residential or any other
sound-sensitive use, any data center building or ancillary
equipment should (1) be located at least 200 feet (61 m)
from the residential or noise-sensitive use or (2) meet the
other standards set out for data centers in the commercial
districts set out in section 1.
a.

A lesser distance that does not conform to the
standards in paragraph 1, above, may be allowed with
special exception approval.

5. MODEL ZONING ORDINANCE GUIDELINES

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6

Appendix, contacts,
and additional resources

Appendix: case studies
Google’s Gmail and the need for redundancy

Google’s financing of a water treatment plant

According to Google’s podcast Where the Internet Lives,
Gmail launched in 2004 while offering a staggering 1 gigabyte
of storage—more than 250 times the capacity of other email
services at the time.

In 2012, Google funded the Sweetwater Creek Sidestream Plant
in Douglas County, Georgia. This move made its nearby data
center the first in the state to use recycled water for cooling.
Google partnered with the Douglasville-Douglas County
Water and Sewer Authority on an initiative to conserve the
Chattahoochee River’s potable water supply, especially during
droughts and summertime.

23

Gmail revolutionized user expectations and increased the need
for data center capacity. It made every individual’s account data
exist on multiple interconnected servers at Google’s hyperscale
data centers, ensuring that users always have access to their
personal information, even in the event of individual server
failures, and allowing users to search and organize emails in a
new way.

The Meta outage and the quest for data center
capacity
The October 2021 Meta outage affected Facebook, Instagram,
WhatsApp, Messenger, Oculus, and other services, making them
inaccessible to billions of users for six to seven hours. This
disruption, caused by an ill-timed and erroneous maintenance
command, led to a cascade of failures that severed Meta’s
data centers from the internet. The primary cause was a lack
of redundancy in the backbone network, which left no failover
capacity for critical services.24
The economic impact was significant, with individuals
and businesses that relied on these services facing major
interruptions—amplified by the fact that many users sign in to
other apps and services through their Facebook logins. As Mike
Isaac and Sheera Frenkel wrote, in the New York Times, this
mix of factors led “to unexpected domino effects such as people
not being able to log into shopping websites or sign into their
smart TVs, thermostats, and other Internet-connected devices.”25
Meta’s stock value dropped by billions of dollars during and
after the outage.26

AWS’ community incentives package in Mississippi
As part of AWS’ $10 billion data center campus investment in
Mississippi—the single largest capital investment in that state’s
history—the company funded Mississippi’s first utility-scale
wind farm, located in Tunica County, and developed STEMfocused workforce training and career awareness programs for
K-12 school systems.
The hyperscaler committed to supporting local educational
institutions—community colleges, technical schools,
universities, and workforce development organizations—by
developing training programs for high-demand career pathways
in data center construction and operations, as well as the
broadband expansion sector. AWS also provided a free cloud
computing curriculum to local institutions and learners.

Fredericksburg, VA’s windfall
Located southeast of Loudoun County, Fredericksburg, Virginia,
is an emerging exurban hyperscale campus market. Alongside
its regional partners, it represents a case study in attracting
data center development—and landmark economic and
fiscal benefits–while also mitigating potential concerns well
in advance.
In March 2024, Virginia’s governor, Glenn Youngkin, alongside
other state and local elected officials, announced that AWS
was making a $35 billion investment in data centers in
Spotsylvania, Caroline, Stafford, and Louisa counties, thereby
creating approximately 2,000 new jobs. It was also announced

23

Fischer Barry, “Two: Inside the Walls,” Where the Internet Lives, December 9, 2020, podcast, 40:54, https://www.google.com/about/datacenters/podcast/.

24

Kerry Sheridan, “Facebook Outage: Social Media Giant Blames Network Problem for Global Disruption,” BBC News, October 4, 2021, https://www.bbc.com/news/
technology-58793174.

25

Mike Isaac and Sheera Frenkel, “Gone in Minutes, Out for Hours: Outage Shakes Facebook,” New York Times, October 4, 2021, https://www.nytimes.
com/2021/10/04/technology/facebook-down.html.

26

Greg Roumeliotis, “Facebook Services, Including Instagram and WhatsApp, Suffer Worldwide Outage,” Reuters, October 5, 2021, https://www.reuters.com/
technology/facebook-instagram-whatsapp-suffer-outage-2021-10-04/.

6. APPENDIX, CONTACTS, AND ADDITIONAL RESOURCES

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that AWS would be contributing $400,000 in community
funds within those four localities, which, together with
bordering Fredericksburg, constitute an economic region: the
Fredericksburg Area Association of Realtors service area.
What Youngkin called the largest single economic development
investment in the history of the state didn’t happen by accident.
The Fredericksburg Regional Alliance (FRA) at the University of
Mary Washington and other regional groups had together been
paving the way for data center development since 2016, when
they also focused on ensuring the facilities would be built away
from residential areas or well-buffered if close to them.
“The reality is [that] this region is one of the [fastest-growing]
areas in the Commonwealth. With growth comes the need
for infrastructure and services that the area can [afford only]
by attracting new revenue sources or raising taxes on local
businesses and residents,” stated Curry Roberts, president of
the FRA, in a local op-ed. “To get ahead of this [need], leaders in
our region have worked for over a decade to attract data centers
and the tremendous local tax revenue they bring.”
According to Roberts, the regional coalition began its quest by
evaluating 50 sites to determine whether—based on zoning,
transmission lines, and water access—they were compatible
with data center use. The coalition eventually narrowed it list
down to 15 locations across five localities, with each site
exceeding 100 acres. This groundwork set the stage for an
ambitious economic development plan aimed at attracting major
industry players such as AWS.
Roberts emphasized the importance of getting information in
front of the public proactively, rather than waiting for opposition
to arise. Stafford County, for example, held several community
meetings to educate people about data centers before any
specific projects were proposed.
Stafford and Spotsylvania counties set the stage for evaporative
cooling by engineering recycled wastewater systems for that
purpose in data centers. These systems are now used by data
centers, which pay for the service, thus creating additional
revenue for the localities.
When AWS approached regional leaders in 2018 about a data
center project, the FRA was able to act quickly. It coordinated
with localities to harmonize tax rates and depreciation schedules
on a parcel that straddled several jurisdictions, ensuring a
straightforward fiscal environment for AWS.
Although the project stalled during the pandemic, by 2023 AWS
had acquired and entitled approximately 2,500 acres (1,012 ha),
paving the way for the development of 18 million to 19 million
square feet (1.7 million–1.8 million sq m) of data center space.

6. APPENDIX, CONTACTS, AND ADDITIONAL RESOURCES

Tax benefits from the investment are immense. According to
Roberts, for every dollar of service demanded by a data center,
the operator is paying $13 in taxes.

Elk Grove Village’s innovation district
Elk Grove Village, Illinois, a suburban community northwest
of downtown Chicago, is located at a major fiber intersection.
It intentionally attracted data center development through a
combination of zoning code modifications, the promotion of
strategic location advantages, and proactive communication with
the development community.
Since its formation, the village has had unique zoning. The
eastern half of the community, adjacent to O’Hare International
Airport, is home to the largest contiguous industrial park in
the United States and is zoned as such. The western half of the
village is primarily residential and zoned to protect housing.
Matthew Roan, the village manager of Elk Grove Village, said
the municipality updated its zoning code to spur redevelopment
within its office park by creating a new “innovation and
technology” zoning district that specifically permitted data
centers as an approved use, thus inviting data center operators
to fill unused space.
Additional modifications to the zoning code allow data centers
to have greater building heights and front-yard fencing or
screening that wouldn’t normally be permitted for industrial
uses. Other changes reduce parking requirements. All of these
changes allow data center builders to get their projects off the
ground more quickly, amid the certainty that the structures
can be built and won’t struggle in the approvals process—an
uncertain phase that makes land acquisition too risky for some
parties.
This proactive approach has attracted data center developers
and hyperscalers, including Meta and Microsoft. Roan, who has
served in various roles in village government since 2000, said
it brought significant economic benefits to the region, including
long-term development and permit fee revenues, financial
assistance for local school districts and other taxing bodies,
high-quality site aesthetics, and temporary construction jobs.
The increased tax and fee revenue from data centers allowed
the village to reinvest in infrastructure improvements and
redevelopment projects, he said.
This strategic positioning of Elk Grove Village as a data center
hub exemplifies how proactive municipal policies can drive
growth and innovation—as well as stable economic returns.
Once data centers make their large capital investments, Roan
said, they tend to stay in the community long term, unlike more
transient industrial users.

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Contacts

Economic development contacts
Andrew Larsen,
Managing Director,
Henrico EDA

Brad Tietz,
Vice President,
Chicagoland Chamber of Commerce

Curry Roberts,
President,
Fredericksburg Regional Alliance
at the University of Mary Washington

[email protected]

[email protected]

540.361.7373
[email protected]

Jackie Russell,
Economic Development Specialist,
New Albany

Matt Roan,
Village Manager,
Elk Grove Village

[email protected]

847.357.4004
[email protected]

Land use and law contacts
Colleen Gillis,
Esq.,
Curata Partners PLLC
(Chantilly, Virginia)

Tamsen Plume,
Partner,
Holland & Knight LLP
(San Francisco, California)

[email protected]
703.202.3130

[email protected]
415.743.6941

6. APPENDIX, CONTACTS, AND ADDITIONAL RESOURCES

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7

Glossary

air-cooled chiller system: A cooling system sealed in a
closed loop that typically consumes very little water—less than
the amount used in three single-family homes.

power distribution units (PDUs): Devices that distribute
energy to servers, network devices, and other equipment within
a rack.

clustering: The practice of data centers locating near one
another, connecting their servers to work as a unified system, or
both.

power purchase agreements (PPAs): An agreement between
a data center company (the buyer) and a renewable energy
provider (the seller) to purchase electricity from specific wind or
solar farms.

colocation data centers: Multi-tenant data centers where
third-party operators (developers) lease data center space—a
certain number of server cabinets, for example, or kilowatts (kW)
to a host of other companies.
corporate data centers: Also called enterprise data centers,
these facilities store and process a single organization’s data.
These data centers often store the data of financial institutions—
think American Express or Wells Fargo—that typically own and
operate such facilities themselves, rather than leasing them from
a provider.
data center: A building or campus that houses the
infrastructure that supports the world’s computing functions.
data hall: The rooms in data centers where data is processed
and stored.
evaporative cooling: A cooling system that uses large fans
to move air across a wet medium to evaporate water, which
removes the heat from the data center and cools the air.
hyperscale data centers: Large data center buildings or
campuses that process and store the data of companies that
often need to scale up or scale down their infrastructure quickly.
hyperscaler: A company that occupies and operates a large
data center building or campus. These companies—which
include AWS, Microsoft, Google and Meta, often need to “scale
up” their infrastructure quickly.
latency: The time it takes for information to travel from its
source to its destination.
load balancing: The process of distributing network traffic
across multiple servers at interconnected data centers.
node: An individual server in a cluster of servers.
phasing: A process for data center campus construction that
occurs in stages.

7. GLOSSARY

purple pipe system: A recycled water setup whereby water is
treated to remove contaminants, solids, and impurities and then
distributed via plum-colored pipes.
renewable energy certificate (REC): A tradable commodity
wherein each REC equates to the generation of 1 MWh of power
from a qualified renewable resource, usually wind or solar power
generation facilities.
switch: A device used to connect network devices and route data
through interconnected networks.
switchgear: Power distribution equipment that controls,
protects, and distributes electrical power throughout the data
center.
telecom data centers: Where traffic from cell towers
“switches” to go out to the internet. Typically owned by such
telecommunications companies as Verizon, these centers tend to
be smaller facilities than the other data center types and require
less than 10 kWs.
uninterruptible power supply (UPS) systems: Electrical
equipment used in data centers to provide battery backup power
in the event of a power outage.
utility substation transformer: A large electrical device in
the electrical yards of a data center campus that steps down
high-transmission voltages from the utility grid to lower, more
manageable medium-voltage levels suitable for distribution
throughout the data center.
water-cooled chiller system: An open-loop pipe system in
which water removes heat from the refrigerant.
wholesale data center: A type of data center where a thirdparty developer rents a large portion of the space, the energy
capacity, or both to one company–often, all of it.

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East Tawas Data Center Amendment
Draft: February 17, 2026
Amendment to Section 44-38, Definitions
Data Center
A building or portion of a building used primarily for the storage, processing, or
transmission of digital data, including servers, data storage or processing systems,
network equipment, power distribution systems, cooling equipment, and associated
support infrastructure. A data center must be characterized by one (1) or more of the
following: uninterruptible power supply (UPS) systems; redundant electrical
distribution; emergency generators; dedicated cooling equipment; raised flooring;
specialized fire suppression systems; and enhanced physical security. The term does not
include accessory server rooms clearly incidental to a permitted principal use containing
a limited amount of information technology equipment serving the internal needs of a
building, typically supported by standard building electrical and mechanical systems,
and not requiring emergency power, redundant distribution, or dedicated cooling
systems.
Large Data Center
A Data Center that meets any of the following thresholds:
1.

Gross floor area greater than 20,000 square feet;

2.

Designed peak electrical demand greater than 3 megawatts (MW); or

3.

Use of water-based cooling systems with projected average water use exceeding
25,000 gallons per day.

Small Data Center
A Principal Use Data Center that does not meet the definition of a Large Data Center.
Accessory Data Center
A Data Center that is incidental and subordinate to a principal permitted use, occupies
no more than 5,000 square feet, and exclusively serves on-site operations.

Amendment to Article 44: Zoning District Regulations
Sec 44-113(b) LI, Limited Industrial District, Permitted Uses
Remove: Data processing equipment and systems
Remove: Data processing and computer centers, including the servicing and
maintenance of electronic data processing equipment
Sec 44-113(c) LI, Limited Industrial District, Accessory Uses
Add: Accessory Data Centers
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East Tawas Data Center Amendment
Draft: February 17, 2026
Sec 44-115(c) I, Industrial District, Accessory Uses
Add: Accessory Data Centers
Sec 44-115(d) I, Industrial District, Special Uses
Add: Small Data Centers
Add: Large Data Centers

New Section: Sec 44-299 Data Centers
A. Purpose and Intent
The purpose of this ordinance is to establish a regulatory framework for siting, design,
operation, and decommissioning of Data Centers in order to balance local economic
benefits with the protection of public health, safety, welfare, natural resources, and
neighborhood character. Standards are intended to:
1. Direct Data Centers to locations with existing and adequate infrastructure,
redevelopment and infill of existing sites, and minimal land-use conflicts;
2. Avoid and mitigate nuisance impacts (noise, vibration, light/glare, air emissions);
3. Ensure efficient consumption and use of electricity and water, prioritizing
renewable energy and conservation;
4. Promote context-appropriate architecture and robust screening;
5. Ensure compatibility with adjacent land uses and the City’s Master Plan; and
6. Ensure responsible decommissioning and site restoration.
B. Design Requirements
1. Minimum Lot Area
o Small Data Center: thirty thousand (30,000) square feet
o

Large Data Center: fifty thousand (50,000) square feet

2. Setbacks
a. Small Data Centers: Minimum distance from front and rear property lines
is fifty (50) feet and side property lines is twenty-five (25) feet
b. Large Data Centers: Minimum distance from front and rear property lines
fifty (50) and side property lines is thirty-five (35) feet
i. 200 feet from any residential used or zoned property.
c. Mechanical equipment must be located as far as practicable from
residential lot lines
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East Tawas Data Center Amendment
Draft: February 17, 2026
3. Building Height
a. Maximum height, including rooftop mechanical equipment and cooling
towers, must comply with the underlying District standards
4. Lot Coverage
a. Maximum lot coverage must not exceed 60% or 200,000 square feet,
whichever area is less
C. Performance Standards
1. Noise
a. For Large Data Centers, the City may require a post-installation acoustical
study prepared by a qualified professional
b. Noise Limit. Routine operations (including cooling equipment) shall not
exceed 50 dBA Leq at the property line. Nighttime (10 p.m.–7 a.m.) limits
adjacent to residential shall be 40 dBA Leq.
c. Generator Testing. Routine testing shall occur between 8:00 a.m.–6:00 p.m.
weekdays. Testing shall comply with the noise limits.
2. Mechanical Equipment and Screening
a. All rooftop and ground-mounted mechanical equipment, including HVAC,
generators, cooling towers, and transformers, must be fully screened from
public streets and residential properties and designed to integrate
architecturally with the building.
b. Cooling towers, generators, and transformers must include noise
attenuation features where necessary to meet performance standards.
3. Energy and Sustainability
a. Efficiency Target. Design for PUE of 1.3 or lower or demonstrate the highest
efficiency reasonably achievable given site constraints; provide
documentation at Site Plan and post-occupancy.
b. Renewable Energy. Demonstrate that greater than 25% of projected annual
energy demand will be met via on-site generation, power-purchase
agreements, renewable energy credits, or utility green-power programs.
c. Heat Reuse. Provide a feasibility analysis for waste-heat recovery or
district-energy interconnection.
d. Reporting. See Section I for annual reporting requirements.
3

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East Tawas Data Center Amendment
Draft: February 17, 2026
e. Water Conservation.
i. Cooling systems must be designed to minimize potable water
consumption, with preference for air-cooled, hybrid, or closed-loop
water systems.
ii. Facilities using water-based cooling must demonstrate the use of
recycled, reclaimed, or non-potable water sources to the maximum
extent feasible.
f. Small and Large Data Center Security and Emergency Access
i. Perimeter Security.
1. Sites must be fully enclosed with a perimeter security system,
which may include fencing, walls, or equivalent barriers not
less than eight (8) feet in height.
2. Security barriers must be designed to balance safety with
community character; opaque fencing must be screened with
landscaping where visible from public roads or residential
areas.
ii. Access Control.
1. All site entrances must include controlled access gates, guard
stations, or equivalent security technology to prevent
unauthorized entry.
2. Visitor and delivery access points must be separated from
employee access points wherever feasible.
iii. Emergency Access.
1. A minimum of two (2) points of emergency vehicle access
must be provided, with clear signage and unobstructed
pathways around the building.
2. Access drives must be constructed to fire department
standards, with sufficient load-bearing capacity for
emergency apparatus.
3. Fire lanes must be maintained free of obstructions at all times.
iv. Cameras.
1. Installation and maintenance of a perimeter camera
surveillance system capable of monitoring all vehicular and
4

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East Tawas Data Center Amendment
Draft: February 17, 2026
pedestrian access points, building entrances, and outdoor
mechanical/equipment areas.
2. Cameras must be positioned to minimize intrusion into
adjoining residential properties and public rights-of-way,
while still providing full coverage of the site.
3. Camera systems must be continuously operational (24 hours
per day, 7 days per week) and recordings must be retained for
a minimum of 30 days.
4. A security plan, including camera layout, monitoring
procedures, and data retention policies, must be submitted as
part of site plan review.
v. Fire Protection.
1. Sites must be equipped with an automatic fire detection and
suppression system designed to protect both building
occupants and sensitive equipment.
2. Suppression systems must comply with National Fire
Protection Association (NFPA) standards and be approved by
the Fire Marshal.
vi. Hazardous Materials.
1. Any use of hazardous materials (including fuels for backup
generators, batteries, and chemicals for cooling systems) must
comply with federal, state, and local storage, reporting, and
disposal requirements.
2. Applicants must provide a Hazardous Materials Management
Plan identifying on-site materials, storage methods, spill
prevention measures, and emergency response procedures.
3. Applicant must provide a fire protection plan.
vii. Emergency Response Plan. Applicants must submit an Emergency
Response Plan to the City at the time of Site Plan review, which must
include:
1. Site layout for emergency responders.
2. Fire suppression and alarm systems description.
3. Backup generator location and fuel storage details.

5

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East Tawas Data Center Amendment
Draft: February 17, 2026
4. Contact information for on-site security and facility
management.
5. Operators must provide annual training opportunities or site
orientations to local fire, police, and emergency medical
services.
4. Battery Energy Storage Systems (if provided)
a. Battery Energy Storage Systems (BESS) shall be an accessory component to
the principal use of the property.
b. BESS shall comply with NFPA 855, the Michigan Building/Fire Codes, and
manufacturer’s specifications.
c. Setbacks. Outdoor BESS containers shall be set back a minimum of 100 feet
from property lines and 300 feet from residential districts/uses, unless a
greater distance is required by NFPA 855 based on technology and
aggregate capacity.
d. Protection. Provide vehicle impact protection, fire rated separation where
required, gas detection, ventilation, and emergency shut offs. Include a
BESS specific emergency response plan and data sheet package.
5. On Site Substation/Switchyard (if provided)
a. Locate to minimize visual and noise impacts; provide evergreen screening
and security fencing consistent with utility standards.
b. Transformers shall include integral secondary containment sized per state
rules.
D. Monitoring and Reporting
1. Commissioning Documentation: Prior to Certificate of Occupancy, submit
commissioning results for mechanical/electrical systems and acoustical
compliance.
2. By March 31 of each year, operators of Large Data Centers must submit an annual
report to the City containing:
3. Energy Use
o

Total annual electricity consumption (MWh)

o

Peak demand (MW)

4. Water Use
6

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East Tawas Data Center Amendment
Draft: February 17, 2026
o

Total annual water consumption (gallons)

o

Cooling system type

5. Noise Compliance
o

Summary of any noise complaints and corrective actions taken

6. Generator Operations
o

Total hours of generator testing and operation

o

Confirmation of compliance with applicable state and federal regulations

Failure to submit the required report may constitute a zoning violation subject to
enforcement under the Zoning Ordinance.
E. Use of Consultants and Cost Recovery
1. The City may retain qualified consultants to review energy efficiency, water
consumption and use, air quality, BESS safety, renewable energy, stormwater,
noise, and related matters.
2. All reasonable costs must be escrowed by the applicant.
F. Decommissioning
1. Plan Required. As a condition of Special Use Permit and Site Plan approval for
Small and Large Data Centers, the applicant must submit a Decommissioning and
Site Restoration Plan that address:
a) Triggers for decommissioning.
b) Methods for removal of structures, equipment, utilities, and impervious
surfaces.
c) Recycling and disposal of equipment and hazardous materials.
d) Final grading, soil stabilization, and revegetation.
e) Restoration of the site to a condition compatible with surrounding uses.
2. Triggers for Decommissioning
a) A center must be considered abandoned if it ceases operations for a period
of 12 consecutive months, unless the owner provides evidence of intent to
resume operations.
b) Decommissioning must begin within 6 months of abandonment and be
completed within 12 months.
7

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East Tawas Data Center Amendment
Draft: February 17, 2026
3. Performance Guarantee / Financial Assurance
a) Prior to issuance of a building permit, the applicant must post a financial
guarantee in the form of a letter of credit, bond, or escrow account
acceptable to the City.
b) The amount must equal 125% of the estimated decommissioning cost, as
determined by a qualified engineer and approved by the City.
c) Estimates must be updated every 5 years and adjusted for inflation.
4. Removal Standards
a) All above-ground structures, including buildings, mechanical equipment,
cooling towers, security fencing, and pavement not otherwise serving a
reuse, must be removed.
b) Below-ground infrastructure, such as foundations and utilities, must be
removed to a minimum depth of 36 inches below grade unless otherwise
approved.
c) Materials must be recycled to the maximum extent practicable.
5. Site Restoration
a) The site must be restored with topsoil, seeded or planted with native
vegetation, and stabilized to prevent erosion.
b) The City may approve alternate restoration plans if the site is proposed for
redevelopment consistent with the Master Plan and Zoning Ordinance.
6. Failure to Decommission
a) If the owner fails to complete decommissioning in accordance with the
approved plan, the City may draw upon the financial guarantee to complete
the work and assess/lien subject parcel(s) for any cost in excess of the
amount of the submitted bond
b) Any costs exceeding the financial guarantee must remain the responsibility
of the property owner.
G. Relationship to Other Ordinance Provisions
Where the standards of this section conflict with other provisions of the Zoning
Ordinance, this section must govern. All other applicable building, fire, environmental,
and utility regulations must apply.

8

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Amendment to Article 2 Definitions
Data Center
A building or portion of a building used primarily for the storage, processing, or
transmission of digital data, including servers, data storage or processing systems, network
equipment, power distribution systems, cooling equipment, and associated support
infrastructure. A data center must be characterized by one (1) or more of the following:
uninterruptible power supply (UPS) systems; redundant electrical distribution; emergency
generators; dedicated cooling equipment; raised flooring; specialized fire suppression
systems; and enhanced physical security. The term does not include accessory server
rooms clearly incidental to a permitted principal use containing a limited amount of
information technology equipment serving the internal needs of a building, typically
supported by standard building electrical and mechanical systems, and not requiring
emergency power, redundant distribution, or dedicated cooling systems.
Large Data Center
A Data Center that meets any of the following thresholds:
•

Gross floor area greater than 20,000 square feet;

•

Designed peak electrical demand greater than 3 megawatts (MW); or

•

Use of water-based cooling systems with projected average water use exceeding
25,000 gallons per day.

Small Data Center
A Principal Use Data Center that does not meet the definition of a Large Data Center.
Accessory Data Center
A Data Center that is incidental and subordinate to a principal permitted use, occupies no
more than 5,000 square feet, and primarily serves on-site operations.

Amendment to Section 6.03.C. Use Groups
Group 5: Mixed Use High Impact
Add: Accessory Data Centers
Group 7: Miscellaneous Commercial
Add: Accessory Data Centers
Group 8: Industrial

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Add: Accessory Data Centers
Add: Small Data Centers
Add: Large Data Centers

New Section 8.23: Data Centers
A. Purpose and Intent
The purpose of this ordinance is to establish a regulatory framework for siting, design,
operation, and decommissioning of Data Centers in order to balance local economic
benefits with the protection of public health, safety, welfare, natural resources, and
neighborhood character. Standards are intended to:
1. Direct Data Centers to locations with existing and adequate infrastructure,
redevelopment and infill of existing sites, and minimal land-use conflicts;
2. Avoid and mitigate nuisance impacts (noise, vibration, light/glare, air emissions);
3. Ensure efficient consumption and use of electricity and water, prioritizing renewable
energy and conservation;
4. Promote context-appropriate architecture and robust screening;
5. Ensure compatibility with adjacent land uses and the City’s Master Plan; and
6. Ensure responsible decommissioning and site restoration.
B. Design Requirements
1. Minimum Lot Area
o Small Data Center: twenty thousand (20,000) square feet
o

Large Data Center: forty thousand (40,000) square feet

2. Setbacks
a. Small Data Centers: Minimum distance from all property lines is twenty-five
(25) feet
b. Large Data Centers: Minimum distance from all property lines is thirty-five
(35) feet
c. Mechanical equipment must be located as far as practicable from residential
lot lines
3. Building Height

Page 57 of 91

a. Maximum height, including rooftop mechanical equipment and cooling
towers, must comply with the underlying District standards
4. Lot Coverage
a. Maximum lot coverage must not exceed 60%
C. Performance Standards
1. Noise
a. For Large Data Centers, the City may require a post-installation acoustical
study prepared by a qualified professional
2. Mechanical Equipment and Screening
a. All rooftop and ground-mounted mechanical equipment, including HVAC,
generators, cooling towers, and transformers, must be fully screened from
public streets and residential properties and designed to integrate
architecturally with the building.
b. Cooling towers, generators, and transformers must include noise attenuation
features where necessary to meet performance standards.
3. Energy and Sustainability
a. Efficiency Target. Design for PUE of 1.3 or lower or demonstrate the highest
efficiency reasonably achievable given site constraints; provide
documentation at Site Plan and post-occupancy.
b. Renewable Energy. Demonstrate that greater than 25% of projected annual
energy demand will be met via on-site generation, power-purchase
agreements, renewable energy credits, or utility green-power programs.
c. Heat Reuse. Provide a feasibility analysis for waste-heat recovery or
district-energy interconnection.
d. Reporting. See Section I for annual reporting requirements.
e. Water Conservation.
i. Cooling systems must be designed to minimize potable water
consumption, with preference for air-cooled, hybrid, or closed-loop
water systems.

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ii. Facilities using water-based cooling must demonstrate the use of
recycled, reclaimed, or non-potable water sources to the maximum
extent feasible.
f. Small and Large Data Center Security and Emergency Access
i. Perimeter Security.
1. Sites must be fully enclosed with a perimeter security system,
which may include fencing, walls, or equivalent barriers not less
than eight (8) feet in height.
2. Security barriers must be designed to balance safety with
community character; opaque fencing must be screened with
landscaping where visible from public roads or residential
areas.
ii. Access Control.
1. All site entrances must include controlled access gates, guard
stations, or equivalent security technology to prevent
unauthorized entry.
2. Visitor and delivery access points must be separated from
employee access points wherever feasible.
iii. Emergency Access.
1. A minimum of two (2) points of emergency vehicle access must
be provided, with clear signage and unobstructed pathways
around the building.
2. Access drives must be constructed to fire department
standards, with sufficient load-bearing capacity for emergency
apparatus.
3. Fire lanes must be maintained free of obstructions at all times.
iv. Cameras.
1. Installation and maintenance of a perimeter camera
surveillance system capable of monitoring all vehicular and
pedestrian access points, building entrances, and outdoor
mechanical/equipment areas.

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2. Cameras must be positioned to minimize intrusion into
adjoining residential properties and public rights-of-way, while
still providing full coverage of the site.
3. Camera systems must be continuously operational (24 hours
per day, 7 days per week) and recordings must be retained for a
minimum of 30 days.
4. A security plan, including camera layout, monitoring
procedures, and data retention policies, must be submitted as
part of site plan review.
v. Fire Protection.
1. Sites must be equipped with an automatic fire detection and
suppression system designed to protect both building
occupants and sensitive equipment.
2. Suppression systems must comply with National Fire
Protection Association (NFPA) standards and be approved by
the Fire Marshal.
vi. Hazardous Materials.
1. Any use of hazardous materials (including fuels for backup
generators, batteries, and chemicals for cooling systems) must
comply with federal, state, and local storage, reporting, and
disposal requirements.
2. Applicants must provide a Hazardous Materials Management
Plan identifying on-site materials, storage methods, spill
prevention measures, and emergency response procedures.
3. Applicant must provide a fire protection plan.
vii. Emergency Response Plan. Applicants must submit an Emergency
Response Plan to the City at the time of Site Plan review, which must
include:
1. Site layout for emergency responders.
2. Fire suppression and alarm systems description.
3. Backup generator location and fuel storage details.

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4. Contact information
management.

for

on-site

security

and

facility

5. Operators must provide annual training opportunities or site
orientations to local fire, police, and emergency medical
services.
D. Monitoring and Reporting
1. Commissioning Documentation: Prior to Certificate of Occupancy, submit
commissioning results for mechanical/electrical systems and acoustical
compliance.
2. By March 31 of each year, operators of Large Data Centers must submit an annual
report to the City containing:
3. Energy Use
o

Total annual electricity consumption (MWh)

o

Peak demand (MW)

4. Water Use
o

Total annual water consumption (gallons)

o

Cooling system type

5. Noise Compliance
o

Summary of any noise complaints and corrective actions taken

6. Generator Operations
o

Total hours of generator testing and operation

o

Confirmation of compliance with applicable state and federal regulations

Failure to submit the required report may constitute a zoning violation subject to
enforcement under the Zoning Ordinance.
E. Use of Consultants and Cost Recovery
1. The City may retain qualified consultants to review energy efficiency, water
consumption and use, air quality, BESS safety, renewable energy, stormwater, noise,
and related matters.
2. All reasonable costs must be escrowed by the applicant.

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F. Decommissioning
1. Plan Required. As a condition of Special Land Use Approval and Site Plan approval for
Small and Large Data Centers, the applicant must submit a Decommissioning and
Site Restoration Plan that address:
a) Triggers for decommissioning.
b) Methods for removal of structures, equipment, utilities, and impervious
surfaces.
c) Recycling and disposal of equipment and hazardous materials.
d) Final grading, soil stabilization, and revegetation.
e) Restoration of the site to a condition compatible with surrounding uses.
2. Triggers for Decommissioning
a) A center must be considered abandoned if it ceases operations for a period of
12 consecutive months, unless the owner provides evidence of intent to
resume operations.
b) Decommissioning must begin within 6 months of abandonment and be
completed within 12 months.
3. Performance Guarantee / Financial Assurance
a) Prior to issuance of a building permit, the applicant must post a financial
guarantee in the form of a letter of credit, bond, or escrow account acceptable
to the City.
b) The amount must equal 125% of the estimated decommissioning cost, as
determined by a qualified engineer and approved by the City.
c) Estimates must be updated every 5 years and adjusted for inflation.
4. Removal Standards
a) All above-ground structures, including buildings, mechanical equipment,
cooling towers, security fencing, and pavement not otherwise serving a reuse,
must be removed.
b) Below-ground infrastructure, such as foundations and utilities, must be
removed to a minimum depth of 36 inches below grade unless otherwise
approved.

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c) Materials must be recycled to the maximum extent practicable.
5. Site Restoration
a) The site must be restored with topsoil, seeded or planted with native
vegetation, and stabilized to prevent erosion.
b) The City may approve alternate restoration plans if the site is proposed for
redevelopment consistent with the Master Plan and Zoning Ordinance.
6. Failure to Decommission
a) If the owner fails to complete decommissioning in accordance with the
approved plan, the City may draw upon the financial guarantee to complete
the work and assess/lien subject parcel(s) for any cost in excess of the amount
of the submitted bond
b) Any costs exceeding the financial guarantee must remain the responsibility of
the property owner.
H. Relationship to Other Ordinance Provisions
Where the standards of this section conflict with other provisions of the Zoning Ordinance,
this section must govern. All other applicable building, fire, environmental, and utility
regulations must apply.

Page 63 of 91

To:

Green Oak Township Planning Commission

From: Paul Montagno, Principal, AICP
Michelle Marin, Associate, AICP
Date: February 11, 2026
Re:

High Resource Demand Facility including Data Centers

Based on direction from the Planning Commission at the February 5, 2026, meeting, we have revised
the draft ordinance language that regulates High Resource Demand Facilities. Substantive edits are
shown in the redlined attachment of the proposed ordinance amendment. The ordinance
amendment includes the following requirements that were discussed at the February 5 th meeting:
1. The maximum building height (45 feet) applies to all heating & cooling towers and mechanical
equipment.
2. The minimum setbacks are required from all private and public roads in addition to all
property lines.
3. Lot coverage explicitly includes ground mounted mechanical equipment.
4. Noise study requirements have been expanded to include all equipment at full operational
load, generator testing, and full backup generator use during an outage.
5. Noise limits are amended to include both continuous noise and impulse noise limits,
measured at all frequencies.
6. Water discharge must comply with applicable state and county permits.
7. Color temperature cannot exceed 3,500 Kelvin.
We look forward to discussing this with you further.
Sincerely,

CARLISLE/WORTMAN ASSOC., INC.
Paul Montagno, AICP
Principal

CARLISLE/WORTMAN ASSOC., INC.
Michelle Marin, AICP
Associate Planner

Page 64 of 91

Green Oak Township –High Demand Facilities Zoning Ordinance Language
February 11, 2026

The Green Oak Township Zoning Ordinance is amended as follows:
SECTION 38-203: High Resource Demand Facilities
A. Purpose and Intent
The purpose of this ordinance is to establish a regulatory framework for siting, design, operation,
and decommissioning of High Resource Demand Facilities, which include data centers and data
processing centers, in order to balance local economic benefits impacts are balanced with
protection of public health, safety, welfare, natural resources, and neighborhood character.
Standards are intended to:
1. Direct High Resource Demand Facilities to locations with existing and adequate
infrastructure, redevelopment and infill of existing sites, and minimal land-use conflicts;
2. Avoid and mitigate nuisance impacts (noise, vibration, light/glare, air pollution and
emissions);
3. Ensure efficient consumption and use of electricity and water, prioritizing renewable
energy and conservation;
4. Promote context-appropriate architecture and robust screening;
5. Ensure compatibility with adjacent land uses and the Township’s Master Plan; and
6. Ensure responsible decommissioning and site restoration.
B. Applicability
1. This section applies to High Resources Demand Facilities, Data Center and Data Processing
Center uses, including Large-Scale, Small-Scale, and Accessory as defined herein.
2. A complete Special Approval Use Permit application and Site Plan application is required
per Section 38-44 and 38-71.
3. Approval is contingent upon the applicant demonstrating conformance to the
requirements of this ordinance and other standards provisions of the Zoning Ordinance
and all other applicable Township Ordinances.
4. Where silent within this provision, other applicable provisions apply (e.g., lighting,
landscaping, stormwater, and performance standards).
C. Definitions
1. High Resource Demand Facility (HRDF): A principal nonresidential facility, campus, or
group of buildings under common ownership or control that is characterized by (i)
continuous or near-continuous operation, and (ii) significant mechanical, electrical, or
cooling infrastructure, and that meets the applicability criteria in subsections (A) and (B)
below.
A facility shall be considered an HRDF only when both of the following are met:
A. Operational Characteristics. The facility includes one or more of the following
operational characteristics that are integral to the primary use:
1. Central plant or large-scale mechanical cooling and/or ventilation systems
serving process loads or IT/electronic equipment;
2
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Green Oak Township –High Demand Facilities Zoning Ordinance Language
February 11, 2026

2. On-site emergency generation with an aggregate nameplate capacity
exceeding 2,000 kW or 2 MW, and/or on-site fuel storage exceeding
10,000 gallons;
3. Dedicated electrical transformation/switchgear yard, substation, or
similarly intensive electrical infrastructure primarily serving the facility;
4. 24-hour operations and/or operational necessity requiring uninterrupted
environmental control (temperature/humidity) or high-reliability power
systems.
B. Resource/Infrastructure Thresholds. The facility exceeds one or more of the
following thresholds, as demonstrated by applicant-prepared estimates and
utility/service provider documentation, including any phased expansion approved
or constructed within five (5) years:
1. Water demand: average daily water consumption > 100,000 gallons/day;
2. Sanitary sewer: average daily sanitary discharge > 50,000 gallons/day;
3. Electric demand: maximum contracted demand or designed peak demand
> 10 MW (or equivalent documented kW);
4. Hazardous materials / regulated wastes: storage, use, or generation
requiring reporting under [EPCRA Tier II and/or applicable state hazardous
materials reporting] and/or generation of hazardous waste at a level
regulated under [state/federal hazardous waste generator requirements],
as documented on a materials inventory submitted with the application.
Exclusions. HRDF does not include general warehousing/distribution, general
manufacturing, or office uses unless the Zoning Administrator determines, based on
operational characteristics and supporting documentation, that the facility is substantially
similar in operational profile to HRDF-type facilities (e.g., high-reliability power demand
and continuous environmental control serving electronic/process loads) and meets
subsections (A) and (B).
Aggregation. Multiple buildings, modules, or phases located on the same site or on
contiguous parcels under common ownership or control shall be aggregated for purposes
of determining HRDF status and whether thresholds are exceeded.
Relationship to Data Centers. A Data Center or Data Processing Center that meets the
HRDF definition shall be considered an HRDF and shall comply with all applicable HRDF
supplemental standards.
2. Data Center: A facility used for the centralized storage, management, processing, and
transmission of digital information, typically containing computer servers, data storage
systems, telecommunications equipment, power distribution systems, cooling and
ventilation systems, uninterruptible power supplies, backup generators, and associated
support infrastructure. The term includes colocation centers, cloud-computing facilities,
hyperscale computing facilities, and similar high-intensity information technology

3
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Green Oak Township –High Demand Facilities Zoning Ordinance Language
February 11, 2026

operations. The term does not include small server rooms, IT closets, or similar equipment
rooms that are clearly accessory and subordinate to another lawful principal use.
3. Data Processing Center: A building or portion of a building used primarily for the
manipulation, analysis, computation, or transformation of digital information through
computer hardware or specialized equipment. A Data Processing Center may include
servers or digital processing equipment but is typically of smaller scale or lower intensity
than a Data Center and may involve office or administrative functions associated with
data manipulation. The term does not include general business offices or accessory server
rooms subordinate to a principal use.
4. Large-Scale Data Center and Data Processing Center: A center equal or greater than
25,000 sq ft gross floor area or located on a site greater than 10 acres.
5. Small-Scale Data Center and Data Processing Center: A center less than 25,000 sq ft, often
serving local or regional networks.
6. Accessory Data Center and Data Processing Center: A center that is clearly incidental and
subordinate to a principal use (e.g., hospital, university, large employer) and less than
10,000 sq ft.
7. Battery Energy Storage System (BESS). One or more electrochemical energy storage
containers, inverters, switchgear, and associated equipment, which may be co-located
with a High Resource Demand Facility to provide resiliency or load management.
8. On-site Substation/Switchyard. Electric utility facilities (e.g., transformers, breakers)
necessary to serve a data center.
9. Water Consumption. The portion of Water Usage that is permanently removed from
immediate availability for reuse within the same watershed as a result of High Resource
Demand Facility operations. Water Consumption includes, but is not limited to, water lost
through evaporation, drift, blowdown discharged to a different watershed, incorporation
into products or waste streams, or other processes that prevent return of the water to
the local hydrologic system in a usable form.
10. Water Usage. The total volume of water withdrawn, diverted, or supplied to a High
Resource Demand Facility from any source, including public water systems, private wells,
surface water, reclaimed water, or other sources, over a specified period of time. Water
Usage includes all water delivered to the facility for cooling, humidification, fire
suppression testing, domestic use, equipment maintenance, or other operational
purposes, regardless of whether such water is later returned to the same watershed,
reused on-site, or discharged as wastewater.

D. Districts Permitted
1. High Resource Demand Facility: Special Approval Use in Data CenterHigh Resource
Demand Facility Overlay District only
2. Large-Scale Data Centers and Data Processing Centers: Special Approval Use in High
Resource Demand FacilityData Center Overlay District only
3. Small-Scale Data Centers and Data Processing Centers: Special Approval Use in High
Resource Demand FacilityData Center Overlay District only

4
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Green Oak Township –High Demand Facilities Zoning Ordinance Language
February 11, 2026

4. Accessory Data Centers and Data Processing Centers: Special Approval Use accessory to
an approved principal use in the GI – General Industrial, LI – Limited industrial, and RO –
Research Office districts only. Prohibited elsewhere.
E. Dimensional Standards
1. Minimum Lot Area:
a) High Resource Demand Facility: 10 acres
b) Large-Scale: 10 acres
c) Small-Scale and Accessory: 2 acres
2. Maximum Building Height, including all mechanical equipment and heating and cooling
towers: 45 feet
3. Maximum Lot Coverage, including all mechanical equipment: 60%
4. Minimum Setbacks:
a) High Resource Demand Facility: 200 feet from all property lines and private or
public right-of-way
b) Large-Scale: 200 feet from all property lines and private or public right-of-way
c) Small-Scale and Accessory: 75 feet from all property lines and private or public
right-of-way
5. Greenbelt:
a) A minimum 50-foot landscaped greenbelt shall be provided along all property
lines.
6. Siting:
a) A High Resource Demand Facility, including but not limited to a Large Scale Data
Center, shall not be located on any parcel that is within 500 feet of any residential
zoned or used property.
F. Site and Design Standards
1. Architecture & Façade Articulation
a) Massing and Scale
1. Building massing, height, bulk, scale, and proportion shall maintain
consistency with the existing character of the adjacent buildings.
2. Building design should employ coordinated massing to produce achieve
overall unity, appropriate scale, and visual interest.
3. Rooflines and pitches shall be proportionate to nearby structures so as to
provide transition or mitigation of significant changes to scale.
b) Architectural design and building materials.
1. Transparency requirements. Transparent elements may include windows,
glazed doors, clerestory windows, or architectural glazing.
a. Ground floor transparency.
1. A minimum of 20 percent of the length of each ground-floor
street-facing façade shall include transparent elements.
2. Minimum Window Spacing. No uninterrupted blank wall
segment exceeding 50 feet in length shall be permitted
along a street-facing façade.
5
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Green Oak Township –High Demand Facilities Zoning Ordinance Language
February 11, 2026

2.

3.

4.

5.

6.

3. Height of Transparency. Required transparent elements
shall be located between 3 feet and 15 feet above finished
grade.
b. Upper-Level Transparency
1. Upper floors visible from a public or private street right-ofway shall include architectural articulation and
transparency equivalent to at least 10 percent of the façade
length.
2. Upper-level transparency may be achieved through
Windows or glazed panels; Spandrel glass or fritted glazing;
Architectural recesses, false window systems; or similar
design features that simulate transparency while
maintaining security.
Façade variation. Wall designs must provide a minimum of three of the
following elements, in addition to transparency requirements, occurring at
intervals no greater than 25 feet horizontally and 10 feet vertically:
a. Expression of structural system and infill panels through change in
plane not less than three inches.
b. System of horizontal and vertical scaling elements, such as belt course,
string courses, cornice, pilasters.
c. System of horizontal and vertical reveals not less than one inch in
width/depth.
d. Variations in material module, pattern, and/or color.
e. System of integrated architectural ornamentation.
f. Green screen or planter walls.
g. Translucent, fritted, patterned, or colored glazing.
Architectural style shall not be restricted. Rather, evaluation of the
appearance of a project shall be based upon compatibility and the quality of
its design and relationship compatibility withto surroundings.
Buildings within the same development should be designed to provide a
unified and easily identifiable image. Methods to achieve this include using
similar architectural styles and materials, complementary roof forms, signs,
and colors.
Minimize monotony of expansive exterior walls by incorporating the
following elements: staggering of vertical walls; recessing openings; providing
upper-level roof overhangs; using deep score lines at construction joints;
contrasting compatible building materials; use of variety and rhythm of
window and door openings; use of horizontal and vertical architectural
elements, use of horizontal bands of compatible colors; and providing
changes in roof shape or roofline.
Facades shall provide visual interest from both vehicular and pedestrian
viewpoints.

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February 11, 2026

c)

7. Entrances to individual buildings shall be readily identifiable to visitors
through the use of recesses or pop-outs, roof elements, columns, or other
architectural elements.
Material standards.
1. Durable building materials, simple configurations, and solid craftsmanship
are required. At least 75% of walls visible from public streetsor private rightsof-way, exclusive of wall areas devoted to meeting transparency
requirements, shall be constructed of brick, glass, metal (beams, lintels, trim
elements, and ornamentation only), wood lap, stucco, split-faced block, or
stone. Vinyl or aluminum siding shall only be used for accents. Exterior
Insulation Finishing Systems (E.I.F.S.) or similar material is not permitted as a
primary building material.
2. Materials shall be selected for suitability to the type of buildings and the
architectural design in which they are used.
3. Material selection shall be consistent with architectural style in terms of
color, shades, and texture; however, monotony shall be avoided.
4. Materials shall be consistent with adjoining buildings.
5. Buildings shall have the same materials, or those that are architecturally
compatible, for construction of all building walls and other exterior building
components wholly or partly visible from public or private rights-of-wayways
and public parking lots.
6. In any design in which the structural frame is exposed to view, the structural
materials shall be compatible within themselves and harmonious with their
surroundings.
7. Transitional features.
a. Transitional features are architectural elements, site features, or
alterations to building massing that are used to provide a transition
between higher-intensity uses and low- or moderate-density
residential areas. These features assist in mitigating potential conflicts
between those uses. Transitional features are intended to be used in
combination with landscape buffers or large setbacks.
b. Intensity. A continuum of use intensity, where moderate-intensity uses
are sited between high-intensity uses and low-intensity uses, shall be
developed for multibuilding developments. An example would be an
office use between commercial and residential uses.
c. Height and mass. Building height and mass in the form of building stepbacks, recess lines or other techniques shall be graduated so that
structures with higher-intensity uses are comparable in scale with
adjacent structures of lower-intensity uses.
d. Architectural features. Similarly sized and patterned architectural
features, such as windows, doors, arcades, pilasters, cornices, wall
offsets, building materials, and other building articulations included on
the lower-intensity use shall be incorporated in the transitional
features.
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2. Mechanical, Loading, and Rooftop Equipment
a) Mechanical equipment shall be fully enclosed unless where mechanically
unfeasible based on manufacturers’ specifications.
b) If located outside of a building, all mechanical equipment (HVAC, generators,
cooling towers, transformers) shall be fully screened by architecturally compatible
walls/panels.
c) Rooftop equipment shall be screened to full height from public or private rightsof-wayviewpoints.
d) Service/loading areas shall be oriented away from residential districts where
feasible and screened per Section 38-177.
3. Lighting
a) Security and area lighting shall comply with Section 38-364: full cut-off fixtures,
down-directed, and shielded to prevent glare and light trespass beyond property
lines.
b) Maximum maintained illuminance at the property line shall not exceed 0.5
foot-candles adjacent to residential and 1.0 foot-candle elsewhere.
b)c)
Color temperature shall not exceed 3,500 Kelvin.
4. Landscaping & Buffers
a) Provide required greenbelts and landscape screening per Section 38-177.
b) Parking lots shall meet interior landscaping ratios; heat-island mitigation via shade
trees is required.
5. Stormwater and Wastewater
a) Stormwater.
1. On-site detention and water-quality treatment are required per the
Livingston County Drain Commission. Designs shall address potential
thermal impacts from large roof/pavement areas and condenser
discharge.
b) Withdrawals/Discharge.
1. Any large-quantity water withdrawal or discharge shall comply with
applicable state and county permits.
6. Traffic and Construction Management
a) A Construction Logistics and Traffic Management Plan is required identifying haul
routes, delivery windows, worker parking, and dust/mud control.
b) Construction hours shall be limited to 7:00 a.m.–7:00 p.m. Monday–Saturday
unless otherwise approved.
G. Performance Standards
1. Noise and Vibration
a) Noise Limit. Routine operations (including cooling equipment and generators)
shall not exceed 50 dBA Leq of continuous noise and 60 dBA Leq of impulse noise
at the property line. Nighttime (10 p.m.–7 a.m.) limits shall not exceed 40 dBA Leq
of continuous noise and 30 dBA of impulse noise. Noise limits shall be measured
at all frequencies from sub-sonic to hyper sonic.

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b) Generator Testing. Routine testing shall occur between 8:00 a.m.–6:00 p.m.
weekdays. Testing shall comply with the noise limits. Noise limits for generator
testing and use of back-up generators during power outages shall not exceed 60
dBA Leq of continuous noise and 100 dBA Leq of impulse noise at the property
line.
c) Measurement Protocol. Compliance shall be demonstrated via pre- and
post-occupancy noise studies by a qualified acoustical engineer; apply penalties
for prominent discrete tones (+5 dB) and impulsive noise per ANSI S12 standards.
The study shall include all proposed development on a lot or site plan and shall be
measured at five (5) feet above grade along the property lines. The noise study
shall address the following circumstances:
1. Expected maximum noise output with all cooling and any other noisegenerating equipment operating simultaneously at full operational load.
2. The use of back-up generators during power outages.
c)3.The routine testing of generators.
d) Vibration. Operations shall not cause perceptible vibration at the property line per
ANSI/ISO criteria.
2. Air Quality and Emissions
a) All stationary engines, cooling towers, and emission sources shall comply with the
federal Clean Air Act and EGLE rules. Required Air Use Permits to Install (PTI) must
be obtained and kept current.
b) Generators. New gGenerators shall meet EPA Tier 4 Final standards. Dispersion
modeling may be required where within 500 feet of residential, schools, parks, or
hospitals.
c) Cooling Towers. Cooling towers shall include drift eliminators and be managed to
prevent particulate emissions or microbial contamination
3. Energy and Sustainability
a) Efficiency Target. Design for Power Usage Effectiveness (PUE) of 1.3 or lower, or
demonstrate the highest efficiency reasonably achievable given site constraints;
provide documentation at Site Plan and post-occupancy.
b) Renewable Energy. Demonstrate that greater than 25% of projected annual
energy demand will be met via on-site generation, power-purchase agreements,
renewable energy credits, or utility green-power programs.
c) Heat Reuse. Provide a feasibility analysis for waste-heat recovery or
district-energy interconnection.
d) Reporting. See Section I for annual reporting requirements.
e) Water Conservation.
1. Cooling systems shall be designed to minimize potable water
consumption, with preference for air-cooled, hybrid, or closed-loop water
systems.
2. Facilities using water-based cooling must demonstrate the use of recycled,
reclaimed, or non-potable water sources to the maximum extent feasible.
f) Security and Emergency Access
1. Perimeter Security.
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2.

3.

4.

5.

6.

a. Sites shall be fully enclosed with a perimeter security system, which
may include fencing, walls, or equivalent barriers not less than
eight (8) feet in height.
b. Security barriers shall be designed to balance safety with
community character; opaque fencing must be screened with
landscaping where visible from a public roads or private right-ofway or residential areas.
Access Control.
a. All site entrances shall include controlled access gates, guard
stations, or equivalent security technology to prevent
unauthorized entry.
b. Visitor and delivery access points must be separated from
employee access points wherever feasible.
Emergency Access.
a. A minimum of two (2) points of emergency vehicle access shall be
provided, with clear signage and unobstructed pathways around
the building.
b. Access drives shall be constructed to fire department standards,
with sufficient load-bearing capacity for emergency apparatus.
c. Fire lanes shall be maintained free of obstructions at all times.
Cameras.
a. Installation and maintenance of a perimeter camera surveillance
system capable of monitoring all vehicular and pedestrian access
points, building entrances, and outdoor mechanical/equipment
areas.
b. Cameras shall be positioned to minimize intrusion into adjoining
residential properties and public or private rights-of-way, while still
providing full coverage of the site.
c. Camera systems shall be continuously operational (24 hours per
day, 7 days per week) and recordings shall be retained for a
minimum of 30 days.
d. A security plan, including camera layout, monitoring procedures,
and data retention policies, shall be submitted as part of site plan
review.
Fire Protection.
a. Sites shall be equipped with an automatic fire detection and
suppression system designed to protect both building occupants
and sensitive equipment.
b. Suppression systems shall comply with National Fire Protection
Association (NFPA) standards and be approved by the Fire Marshal.
Hazardous Materials.
a. Any use of hazardous materials (including fuels for backup
generators, batteries, and chemicals for cooling systems) shall

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February 11, 2026

comply with federal, state, and local storage, reporting, and
disposal requirements.
b. Applicants shall provide a Hazardous Materials Management Plan
identifying on-site materials, storage methods, spill prevention
measures, and emergency response procedures.
c. Applicant shall provide a fire protection plan to be reviewed and
approved by the Township Fire Marshall.
7. Emergency Response Plan. Applicants shall submit an Emergency
Response Plan to the Township at the time of Site Plan review, which must
include:
a. Site layout for emergency responders.
b. Fire suppression and alarm systems description.
c. Backup generator location and fuel storage details.
d. Contact information for on-site security and facility management.
e. Operators shall provide annual training opportunities or site
orientations to local fire, police, and emergency medical services.
4. Battery Energy Storage Systems (if provided)
a) Battery Energy Storage Systems (BESS) shall be an accessory component to the
principal use of the property.
b) BESS shall comply with NFPA 855, the Michigan Building/Fire Codes, and
manufacturer’s specifications.
c) Setbacks. Outdoor BESS containers shall be set back a minimum of 100 feet from
property lines and 300 feet from residential districts/uses, unless a greater
distance is required by NFPA 855 based on technology and aggregate capacity.
d) Protection. Provide vehicle impact protection, fire-rated separation where
required, gas detection, ventilation, and emergency shut-offs. Include a
BESS-specific emergency response plan and data sheet package.
5. On-Site Substation/Switchyard (if provided)
a) Locate to minimize visual and noise impacts; provide evergreen screening and
security fencing consistent with utility standards.
b) Transformers shall include integral secondary containment sized per state rules.
H. Use of Consultants and Cost Recovery
1. The Township may retain qualified consultants to review energy efficiency, water
consumption and use, air quality, BESS safety, renewable energy, stormwater, noise, and
related matters.
2. All reasonable costs shall be escrowed by the applicant.
I. Monitoring and Reporting
1. Commissioning Documentation: Prior to Certificate of Occupancy, submit commissioning
results for mechanical/electrical systems and acoustical compliance.
2. Annual Report (by March 31):
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February 11, 2026

a) Actual annual energy consumption (MWh) and calculated PUE;
b) Renewable energy procurement and percentage of total load;
c) Water consumption (gallons) and cooling method;
d) Generator testing/operating hours and emissions compliance statement with
current EGLE permits;
e) Noise level monitoring summary; and
f) Summary of efficiency/cooling/security upgrades implemented.
3. Failure to monitor and report may be grounds to revoke any township approvals.
J. Decommissioning
1. Plan Required. As a condition of Special Approval Use and Site Plan approval, the applicant
shall submit a Decommissioning and Site Restoration Plan that address:
a) Triggers for decommissioning.
b) Methods for removal of structures, equipment, utilities, and impervious surfaces.
c) Recycling and disposal of equipment and hazardous materials.
d) Final grading, soil stabilization, and revegetation.
e) Restoration of the site to a condition compatible with surrounding uses.
2. Triggers for Decommissioning
a) A center shall be considered abandoned if it ceases operations for a period of 12
consecutive months, unless the owner provides evidence of intent to resume
operations.
b) Decommissioning must begin within 6 months of abandonment and be completed
within 12 months.
3. Performance Guarantee / Financial Assurance
a) Prior to issuance of a building permit, the applicant shall post a financial guarantee
in the form of a letter of credit, bond, or escrow account acceptable to the
Township
b) The amount shall equal 125% of the estimated decommissioning cost, as
determined by a qualified engineer and approved by the Township.
c) Estimates and the financial guarantee must be updated every 5 years and adjusted
for inflation.
4. Removal Standards
a) All above-ground structures, including buildings, mechanical equipment, cooling
towers, security fencing, and pavement not otherwise serving a reuse, shall be
removed.
b) Below-ground infrastructure, such as foundations and utilities, shall be removed
to a minimum depth of 36 inches below grade unless otherwise approved.
c) Materials shall be recycled to the maximum extent practicable.
5. Site Restoration
a) The site shall be restored with topsoil, seeded or planted with native vegetation,
and stabilized to prevent erosion.
b) The Township may approve alternate restoration plans if the site is proposed for
redevelopment consistent with the Master Plan and zoning ordinance.
6. Failure to Decommission
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Green Oak Township –High Demand Facilities Zoning Ordinance Language
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a) If the owner fails to complete decommissioning in accordance with the approved
plan, the Township may draw upon the financial guarantee to complete the work
and assess/lien subject parcel(s) for any cost in excess of the amount of the
submitted bond.
b) Any costs exceeding the financial guarantee shall remain the responsibility of the
property owner.

13
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Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, (c) OpenStreetMap contributors,
Pageand
77the
of GIS
91 User
Community, Esri, NASA, NGA, USGS, FEMA

City of Ypsilanti
Community Services Department
March 18th, 2026
Text Amendment Staff Review
Data Centers

GENERAL INFORMATION
Staff’s Requested Action

Proposed zoning text amendment to permit and establish regulations for
harm reduction services. The amendment includes the following sections
of the Ordinance:
Definitions
Permissible Use Charts
Use-Based Regulations

SUMMARY

BACKGROUND

CURRENT ORDINANCE
PROPOSED ORDINANCE
Amendments can be referenced by Red text with a strikethrough being deleted; green text underlined is
proposed to be added. Sections shall be renumbered accordingly.
Section 122-203. Definitions. A (New Language)
Accessory Data Center means a facility consisting of computer servers and related equipment used for the
storage, management, processing, and/or transmission of digital data that is operated solely to support the
internal operations of the business, institution, or organization located on the same property.
Section 122-203. Definitions. D (New Language)
Data Center means a facility or campus consisting of one or more buildings used primarily for the storage,
management, processing, or transmission of digital data through computer servers and related equipment,
including associated cooling systems, electrical infrastructure, and backup power generation, that operates
as a principal use and is typically associated with large-scale data processing, cloud computing, or
colocation operations.
Section 122-203. Definitions. P (New Language)

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Power Utilization Effectiveness (PUE) means a metric that measures the energy efficiency of a data
center by comparing the total energy used by the facility to the energy used by the information technology
(IT) equipment within the facility.

Section 122-416. Park District Permissible Uses Chart (Amended Language)
P=Principal, A=Accessory, S=Special Land Use
SPECIFIC
NOTES
REGULATIONS

USES
INFRASTRUCTURE
Essential Services

P

Section 122-524

Solar Farms

S

Section 122-513

Alternative Energy

A

Section 122-513

Parking Garage

S

Accessory Data Center

A

Section 122-518
Non-residential uses
only.

Section 122-421. Single-Family Residential District Permissible Uses Chart (Amended
Language)
P=Principal, A=Accessory, S=Special Land Use
SPECIFIC
NOTES
REGULATIONS

USES
INFRASTRUCTURE

R1

Essential Services

P

Section 122-524

Communication Devices

A

Article V, Division 3

Alternative Energy

A

Section 122-513

Accessory Data Center

A

Non-residential uses only.

Section 122-426. Multiple Dwelling Residential District Permissible Uses Chart
(Amended Language)
P=Principal, A=Accessory, S=Special Land Use
SPECIFIC
USES
MD NOTES
REGULATIONS
INFRASTRUCTURE
Essential Services
Communication
Devices
Alternative Energy
Automobile Share
Parking
Accessory Data Center

P
A

Section 122-524
Article V, Division 3

A
A

Section 122-513

A

Non-residential uses only.

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Section 122-431. Production, Manufacturing, and Distribution District Permissible Uses Chart
(Amended Language)
P=Principal; A=Accessory;
S/Res= Special Land Use when adjacent to R-1, CN, CN-Mid, CN-SF, or MD zoning, otherwise
permitted;
S=Special Land Use
SPECIFIC
USES
PMD NOTES
REGULATIONS
INFRASTRUCTURE
Essential Services

P

Section 122-524

Communication Devices

A

Article V, Division 3

Radio & Television Studios or Stations

P

Radio and television towers, public utility
microwaves, and public utility television
transmitting towers, mobile communications
towers, cellular phone towers and their
accessory facilities

P

Utility buildings including electric and gas
service buildings and yards, telephone
exchange buildings, electrical transformer
stations and substations, gas regulator
stations, and water and propane tank holders.

P

Railroad yards not including manufacture and
repair
Energy, electricity and heat generation plants

S/Res

Landfill

S

Water or sewage treatment plant
Biofiltration Facility

S
P

Alternative Energy

A

Accessory Data Center

A

Small Data Center

S/Res

Large Data Center

S

Article V, Division 3

S

Includes solar farms
and geothermal
plants
May include
anaerobic digester.

Section 122-513

Section 122-513
Non-residential uses
only.

Section 122-441. Core Neighborhoods District Permissible Uses Chart (Amended Language)
P=Principal, A=Accessory, S=Special Land Use, -- = Not Permitted

CNSF

CNMI
D
CN NOTES

SPECIFIC
REGULATIONS

Essential Services

P

P

P

Section 122-524

Communication Devices

A

A

A

Article V, Division 3

Alternative Energy

A

A

A

Section 122-513

A

A

Accessory Data Center

A

USES
INFRASTRUCTURE

Non-residential
uses only.

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Section 122-446. Center District Permissible Uses Chart (Amended Language)
P=Principal, A=Accessory, S=Special Land Use

USES

C

NOTES

SPECIFIC REGULATIONS

INFRASTRUCTURE
Essential Services

P

Section 122-524

Communication Devices

A

Article V, Division 3

Alternative Energy

A

Section 122-513

Public & Private Transportation
Passenger Terminals

S

Section 122-548

Accessory Data Center

A

Non-residential uses only.

Section 122-451. Corridors District Permissible Uses Chart (Amended Language)
P=Principal, A=Accessory, S=Special Land Use, -- = Not Permitted

USES

HC

NC

GC

NOTES

SPECIFIC REGULATIONS

Essential Services

P

P

P

Section 122-524

Communication Devices

A

A

A

Article V, Division 3

Alternative Energy

A

A

A

Section 122-513

Accessory Data Center

A

A

A

Small Data Center

--

--

S

INFRASTRUCTURE

Non-residential uses only.

Section 122-461. Health and Human Services District Permissible Uses Chart (Amended
Language)
P=Principal, A=Accessory, S=Special Land Use

USES
INFRASTRUCTURE

HHS

NOTES

SPECIFIC REGULATIONS

Essential Services

P

Section 122-524

Communication Devices

A

Article V, Division 3

Alternative Energy

A

Section 122-513

Accessory Data Center

A

Non-residential uses only.

4

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Section 122-000. Accessory Data Centers
Accessory Data Center.
(a) Scale.
(1) Shall not exceed 5,000 sq ft. If located within the principal building, the data center shall not exceed
20% of total gross floor area.
(b) Performance Standards.
i.
Noise Limit. Routine operations (including cooling equipment) shall not exceed 50 dBA Leq
at the property line. Nighttime (10 p.m.–7 a.m.) limits adjacent to residential shall be 40 dBA
Leq.
ii.
Energy Consumption. Electrical demand shall not exceed 1 megawatt (MW) annually.
iii.
Applications shall identify the type of cooling system used and describe measures taken to
minimize potable water consumption.
iv.
All effluent discharge shall flow into the YCUA wastewater system.
(c) Accessory Buildings. If the data center is located within an accessory building, the building shall be a
minimum distance of 15 feet from the side and rear property lines and shall be screened in accordance
with Section 122-634

Section 122-000. Data Centers as Principal Use
(a) Data Center Scalability.
(1) Small Data Center Scalability
i. Principal building shall not exceed 20,000 sq ft.
ii. Electrical demand shall not exceed 5 megawatts (MW) annually.
iii. Water-based cooling systems shall not exceed 20,000 gallons a day.
iv. A small data center shall be located on a lot containing not less than 1 acre
(2) Large Data Center Scalability
i. Principal building exceeds 20,000 sq ft.
ii. Electrical demand exceeds 5 megawatts (MW) annually.
iii. Water-based cooling systems exceed 20,000 gallons a day.
iv. A large data center shall be located on a lot containing not less than 5 acres.
(b) Design Requirements.
(1) Setbacks.
i. Street Setback (front or side): Shall comply with the underlying zoning district.
ii. Side Setback (interior lot line): fifteen (25) feet minimum.
iii. Rear Setback: twenty-five (25) feet minimum.
(2) Building Height. The maximum height shall comply with the underlying zoning district.
(3) Lot coverage. Maximum lot coverage shall not exceed 60%.
(4) Accessory buildings shall be a minimum distance of 15 feet from the side and rear property lines
and shall be screened in accordance with Section 122-634.
(c) Performance Standards.
(1) Noise.
i. Noise Limit. Routine operations (including cooling equipment) shall not exceed 50
dBA Leq at the property line. Nighttime (10 p.m.–7 a.m.) limits adjacent to
residential shall be 40 dBA Leq.
ii. The city may require a post-installation acoustical study prepared by a qualified
professional.
(2) Energy and Sustainability

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i. Efficiency. Design for PUE of 1.3 or lower or demonstrate the highest efficiency
reasonably achievable given site constraints; provide documentation at Site Plan
and post-occupancy.
ii. Energy consumption. Data centers shall be required to develop or purchase
sufficient new renewable energy to offset 100 percent of the electricity consumed by
the operation. To meet this condition, the operation must be able to establish that
their actions will introduce new renewable energy onto the electrical grid beyond
what would have been developed otherwise.
(3) Water Use.
i. Applications shall identify the type of cooling system used and describe measures
taken to minimize potable water consumption.
ii. Open-loop water-based cooling systems are not permitted on parcels within the
Huron River or Paint Creek floodplains.
iii. All effluent discharge shall flow into the YCUA wastewater system.
(d) Architectural Requirements.
(1) Primary building façades visible from a public right-of-way shall utilize materials such as brick,
stone, architectural metal panels, glass, fiber cement panels, and other comparable materials.
(2) A minimum of thirty percent (50%) of the primary facade shall be comprised of windows, doors, or
similar fenestration design features such as faux windows that are generally distributed horizontally
and vertically across the façade.
(3) Mechanical Equipment Screening. All rooftop and ground-mounted mechanical equipment, including
but not limited to HVAC, generators, cooling towers, and transformers, must be fully screened from
public streets and residential properties and designed to integrate architecturally with the building.
(e) Commissioning Documentation. Prior to issuance of a Certificate of Occupancy, the applicant shall
provide documentation confirming that major mechanical and electrical systems have been installed and
are operating in accordance with approved plans
(1) Annual Reporting. Operators of Large Data Centers shall submit an annual report to the City by
March 31 containing the following:
i. Total annual electricity consumption and peak electrical demand.
ii. Total annual water consumption and cooling system type.
iii. Summary of any noise complaints and corrective actions taken.
iv. Total hours of backup generator testing and operation
v. Failure to submit the required report constitutes a violation of this Ordinance.
vi. Consultant Review.
1. The city may retain qualified consultants to review technical aspects of a
proposed data center, including energy use, water consumption, noise, air
quality, battery energy storage systems, and other relevant matters.
2. All reasonable costs shall be escrowed by the applicant.

Section 122-691. Minimum and Maximum Number of Parking Spaces. (Revised Language)
USES
INFRASTRUCTURE

AUTOMOBILE SPACES PER UNIT OF MEASURE

Radio & Television Studios or
Stations
Utility buildings

1 per each 500 square feet of gross floor area.

Energy, electricity, heat
generation, or sewage plants

1 for each employee on an average employment shift.

1 for each employee on an average employment shift.

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Section 122-691. Minimum and Maximum Number of Parking Spaces. (Revised Language)
USES

AUTOMOBILE SPACES PER UNIT OF MEASURE

Small Data Center

1 for each employee on an average employment shift.

Large Data Center

1 for each employee on an average employment shift.

STANDARDS FOR AMENDMENTS

§122-362(a)

(a) Text Amendment. For a change to the text of the Zoning Ordinance, the Planning Commission shall
consider and the City Council may consider, whether the proposed amendment meets the following standards:
(1) The proposed amendment is consistent with the guiding values of the Master Plan; and
(2) The rezoning is consistent with description and purpose of the proposed district; and (Staff Note: This is not
a rezoning.)

(3) The proposed amendment is consistent with the intent of this Zoning Ordinance; and
(4) The proposed amendment will enhance the functionality, transportation network or character of the future
development in the City; and
(5) The proposed amendment will preserve the historic nature of the surrounding area and of the City; and
(6) The proposed amendment will enhance the natural features and environmental sustainability of the City; and
(7) The proposed amendment will protect the health, safety, and general welfare of the public; or
(8) The proposed amendment is needed to correct an error or omission in the original text; or
(9) The proposed amendment will address a community need in physical or economic conditions or development
practices; and
(10) The proposed amendment will not result in the creation of significant nonconformities in the City.

RECOMMENDED MOTION
--

Joshua Burns,
City Planner

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City of
Ypsilanti
Pride. Diversity. Heritage.

Zoning Text Amendment:
Party Stores
Attachments:
-

Baseline Text Amendment Report
o Further information will be provided during the
meeting.

Ff

1
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City of Ypsilanti
Community Services Department
April 15th, 2026
Text Amendment Staff Review
Party Stores

GENERAL INFORMATION
Staff’s Requested Action

SUMMARY

BACKGROUND

1

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CURRENT ORDINANCE

Section 122-446. Center District Permissible Uses Chart (Amended Language)
P=Principal, A=Accessory, S=Special Land Use

USES

C

NOTES

SPECIFIC REGULATIONS

COMMERCIAL
Retail stores

P

Resale stores

P

Arts & crafts studios

P

Section 122-451. Corridors District Permissible Uses Chart (Amended Language)
P=Principal, A=Accessory, S=Special Land Use, -- = Not Permitted

USES

HC

NC

GC

S

P

P

--

--

P

--

P

P

NOTES

SPECIFIC REGULATIONS

COMMERCIAL
Retail stores, less than
15,000 square feet
Retail stores, greater than
15,000 square feet
Resale stores

PROPOSED ORDINANCE
Amendments can be referenced by Red text with a strikethrough being deleted; green text underlined is
proposed to be added. Sections shall be renumbered accordingly.
Section 122-203. P – Party Stores
A retail establishment where the principal or a substantial portion of business activity consists of the sale of
alcoholic beverages for off-premises consumption, and which may also include the sale of tobacco products,
nicotine products, electronic nicotine delivery systems (ENDS), vapor products, and related accessories. For the
purposes of zoning, this use includes, but is not limited to, liquor stores, vape shops, and convenience stores;
however, this use does not include marihuana retailers or microbusinesses, restaurants, bars, or breweries with
on-premises consumption as the primary use, or grocery stores exceeding 15,000 square feet where alcohol
sales are incidental.

Section 122-446. Center District Permissible Uses Chart (Amended Language)
P=Principal, A=Accessory, S=Special Land Use

USES

C

NOTES

SPECIFIC REGULATIONS

COMMERICAL

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Section 122-446. Center District Permissible Uses Chart (Amended Language)
P=Principal, A=Accessory, S=Special Land Use

USES

C

Retail stores

P

Resale stores

P

Party Stores

S

Arts & crafts studios

P

NOTES

SPECIFIC REGULATIONS

Section 122-548

Section 122-451. Corridors District Permissible Uses Chart (Amended Language)
P=Principal, A=Accessory, S=Special Land Use, -- = Not Permitted

USES

HC

NC

GC

NOTES

SPECIFIC REGULATIONS

COMMERCIAL
Retail stores, less than
15,000 square feet
Retail stores, greater than
15,000 square feet
Resale stores

S

P

P

--

--

P

--

P

P

Party Stores

--

S

P

Section 122-548

Section 122-548. Party Stores
A retail establishment shall be classified as a Party Store if they meet one or more of the following:
a) Floor Area Threshold. Ten percent (10%) or more of the gross floor area is devoted to the display,
storage, or sale of alcoholic beverages and/or tobacco, nicotine, or vapor products;
b) Display Area Threshold. Twenty percent (20%) or more of the total display area, or more than 20
linear feet of shelving, is dedicated to alcoholic beverages and/or tobacco, nicotine, or vapor products;
or
c) Revenue Threshold. Twenty-five percent (25%) or more of the establishment’s gross sales are derived
from alcoholic beverages and/or tobacco, nicotine, or vapor products; or
d) Cooler Capacity Threshold. The establishment contains four (4) or more cooler doors dedicated to the
display of alcoholic beverages.
This section is intended to regulate land use and associated impacts and shall not be construed to regulate or
supersede state and/or federal licensing authority. Party stores shall be permitted subject to the conditions
hereinafter imposed:
a) Locational Requirements.
(1) Party stores shall not be located within one thousand (1,000) feet of another lawfully
established party store;
(2) Party stores shall not be located within one-half (1/2) mile of a primary and/or secondary
schools.
b) Use of alcohol, nicotine, or other similar products is prohibited on premises;
c) All activity related to the marihuana retailer and/or provisioning center shall be done indoors;
d) The premises shall be open for inspection upon request by the Building Official, the Fire Department,
and law enforcement officials for compliance with all applicable laws and rules, during the stated hours
of operation/use and as such other times as anyone is present on the premises.

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STANDARDS FOR AMENDMENTS

§122-362(a)

(a) Text Amendment. For a change to the text of the Zoning Ordinance, the Planning Commission shall
consider and the City Council may consider, whether the proposed amendment meets the following standards:
(1) The proposed amendment is consistent with the guiding values of the Master Plan; and
(2) The rezoning is consistent with description and purpose of the proposed district; and (Staff Note: This is not
a rezoning.)

(3) The proposed amendment is consistent with the intent of this Zoning Ordinance; and
(4) The proposed amendment will enhance the functionality, transportation network or character of the future
development in the City; and
(5) The proposed amendment will preserve the historic nature of the surrounding area and of the City; and
(6) The proposed amendment will enhance the natural features and environmental sustainability of the City; and
(7) The proposed amendment will protect the health, safety, and general welfare of the public; or
(8) The proposed amendment is needed to correct an error or omission in the original text; or
(9) The proposed amendment will address a community need in physical or economic conditions or development
practices; and
(10) The proposed amendment will not result in the creation of significant nonconformities in the City.

RECOMMENDED MOTION
Motion to --- the proposed text amendment to Section 122-000, with the following findings:
(Note: If the Planning Commission is not comfortable with the proposed amendment as provided, the Planning
Commission can recommend changes to the tex
t so long as proposed changes are clearly covered in the motion.)

Joshua Burns,
City Planner, City of Ypsilanti

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