On the agenda: Otsego meeting — DATA CENTER (Jul 6)

1. Agenda And Items
Documents:
07-06-26 PLANNING COMMISSION AGENDA.PDF
ITEM 1. ZONING ORDINANCE-DATA CENTERS.PDF

SPECIAL PLANNING COMMISSION
AGENDA
Monday, July 6, 2026

Otsego Fire Station Tour located at 14499 75th Street NE
at 6:00 PM with work session to follow
The Planning Commission advises the City Council in matters relating to land use and development of the City. The
Planning Commission participates in establishment of the Comprehensive Plan, Zoning Ordinance, Subdivision
Ordinance, and other development related policies and controls. The Planning Commission also reviews
development proposals, including conduct of public hearings when required by law, and makes recommendations
to the City Council.

Call to Order
Roll Call
1. Planning Items:
1.1 Zoning Ordinance Amendments
2. Updates:
2.1 Updates on City Council actions
2.2 Updates on future Planning Commission Items

NOTES:
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make your comments from the podium and identify yourself by your first and last name and your address for the record. Please limit your
comments to three minutes.
Information: The Planning Commission has been provided background information for agenda items in advance by City staff. Decisions are based
on this information, as well as the Comprehensive Plan, City Code, City policy and practices, input from the public and a Commissioner's personal
judgment.
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information.
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3601 Thurston Avenue
Anoka, MN 55303
763.231.5840
[email protected]

MEMORANDUM
TO:

Otsego Planning Commission

FROM:

D. Daniel Licht

DATE:

2 July 2026

RE:

Otsego – Zoning Ordinance; Data Centers

TPC FILE:

101.01

BACKGROUND
Considerable attention is being given to the development of data centers in Minnesota and nationwide
as the demand for these facilities has increased with the expansion of internet-based services resulting
in both more facilities and larger facilities. Proposals for data center developments have generated
controversy due to perceptions about potential impacts and compatibility concerns in other
communities. Otsego has not received an application for development of a data center, and no known
projects are pending.
It is advantageous for the City to anticipate potential development of various land uses in establishing
allowed uses and performance standards within the Zoning Ordinance. This approach allows a broader
consideration of the characteristics of, and potential issues associated with, various land uses and how
to allow and regulate them instead of having to react to an application for a specific project. The City
Council Administrative Subcommittee raised the question as to how data centers are regulated by the
City and directed the Planning Commission to study this matter in further detail. This memorandum
outlines initial topics for consideration related to data centers as a land use and potential regulations.
The Planning Commission will discuss data center regulatory concepts at a work session on 6 July 2026.
Exhibits:
• Future Land Use Plan map
• Understanding Data Centers, National League of Cities
• Data Centers; Zoning Practice Issue #6, APA, June 2022
• The Physical Footprint of Artificial Intelligence; Zoning Practice Vol. 42, APA, October 2025

1

ANALYSIS
Definition. The Zoning Ordinance does not include a definition of data center as a distinct land use in
Section 11-2-2. To establish regulations to address the specific characteristics of data centers, adopting
definitions will be necessary. The regulation of data centers is intended to apply to facilities as a
principal use of property, taking one of two forms. The first is a stand-alone facility within a single
building that may be owned or operated for one business operation. The other, which is the source of
most interest and controversy, is a data center campus (or data farm) having multiple principal buildings
providing internet-based services as a core business function. City staff has drafted the following initial
definitions for future inclusion in the Zoning Ordinance, which would not include accessory uses:
•

Data center: A facility within a single building used primarily for the storage,
management, processing, and transmission of digital data, which houses computer or
network equipment, systems, services, appliances, and other associated components
related to digital data storage and operations, together with its accessory and
appurtenant facilities, which may also include offices, air handlers, back-up power
generators, water cooling systems and water storage facilities, utility substations, and
other associated infrastructure necessary to support sustained operations at a data
center.

•

Data center campus: A facility comprised of more than one data center building, that may
be located upon one property or contiguous properties owned or operated by a single
business operation ol that are otherwise interconnected by power supply, communication
systems, power generation or other operational systems to form a unified data center
facility. This definition includes uses described by terms such as “technology campus”,
“cloud computing campus” or similar phrases and terms.

Land Use. Data center operations are a form of commercial or industrial activity. Data centers provide
services, but do not involve extensive office operations. Data centers do not involve physical industrial
processes such as manufacturing, assembly, processing, or warehousing and do not generate significant
traffic either from passenger vehicles or semi-tractor/trailers. The site and building plans are industrial
with precast concrete buildings or similar industrial building types. Data centers may also have
equipment such as cooling systems, electric transformers, or generators outside of principal buildings.
The Future Land Use Plan map guides areas within the City for development of commercial, office, and
industrial activities. Based on the characteristics of data centers, they would be appropriately located on
properties guided for Office or Industrial land uses.
Office land uses have been guided for properties adjacent to Commercial land uses with the intent of
developing smaller-scale, high-employment operations that would serve to provide daytime market
support for commercial retail and service businesses to increase market vitality.
Data centers are likely most appropriately addressed as industrial uses to be allowed only in areas
guided for Industrial land use by the Future Land Use Plan.

2

Zoning Districts. The City has statutory authority as a legislative action to determine the zoning districts
in which specific uses are to be allowed. The Zoning Ordinance currently allows data centers as a
permitted use within the B-4, Business Office District; I-1, Limited Industrial District; and I-2, General
Industrial District.
Based on the land use discussion above, data centers should not continue to be an allowed use within
the B-4 District.
Inclusion of data centers in the I-1 District and the I-2 District is appropriate from a land use perspective,
but allowance as a permitted use may be problematic. Permitted uses are allowed within various zoning
districts subject to compliance with the performance standards of the Zoning Ordinance. Section 11-9-2
of the Zoning Ordinance provides that proposals for specific developments within the I-1 District and the
I-2 District require applications for site and building plan review that are subject to review by the
Planning Commission and approval of the City Council. No public hearing is required by State Statute or
the Zoning Ordinance for site and building plan review applications. Site and building plan review
decisions are to be based strictly on established performance standards; there is no opportunity for
discretion related to potential impacts of a specific development such as for compatibility with the
surrounding area, impacts on traffic, or impacts to City services and infrastructure.
Uses allowed as conditional uses within a zoning district are subject to a more robust review process
that affords the City authority, albeit still limited, to consider proposal specific factors and includes
opportunity for public input through a required public hearing. Due to perceived concerns for potential
negative impacts of data centers including, but not limited to, water use, electric service demands,
noise, exterior lighting, City staff recommends that continued allowance of data centers within the City
be as a conditional use. However, itt must be emphasized that the conditional use review process
provides discretion only within adopted standards and legally supported conditions; community
opposition to a proposed development alone is not legal justification for a conditional use permit
application to be denied.
Defining data centers as a single principal building and data center campuses as multiple principal
buildings or properties under common ownership and operation also allows the City to determine
where data center uses are appropriate based on their intensity. The City may elect to allow data
centers in both the I-1 District and the I-2 District, while allowing data center campuses only in the I-2
District. The size of the facility in terms of building square footage or service capacity may also be used
to determine appropriate location for data centers by zoning district. Determining whether to allow
data centers and data center campuses as a conditional use in one or both the I-1 District and I-2 District
should consider the locations guided by the Future Land Use Plan for light industrial and industrial land
uses corresponding to these zoning districts, respectively.
Lot Requirements. The Zoning Ordinance establishes minimum lot area and width requirements for
each zoning district for the purpose of subdividing larger tracts into smaller lots that can be feasibly
developed with the uses allowed within the zoning district. The minimum lot area and width
requirements are supplemented by building coverage and impervious surface limits to control the bulk
of development within a lot, provide greenspace for screening and aesthetics, and facilitate stormwater
management. As these standards are minimums, the larger or more intense the use of a property, these
standards (together with minimum setback requirements) may result a larger lot area to offset the
increased intensity of the use. A requirement for data centers to have a larger minimum lot area, lot
width, or specific building coverage and impervious surface limits may be considered as a means of
providing physical separation of a data center from surrounding uses.
3

Setback. Minimum setbacks from property lines are established generally for each zoning district. The
primary purpose of setbacks is physical separation from public streets for visibility or from surrounding
land uses for compatibility and aesthetic reasons. Setback requirements also work to facilitate functional
site plans in terms of access and circulation within a lot and avoidance of congestion on public streets.
A setback requirement may also be established for specific uses to provide for increased separation
from surrounding uses that may be potentially sensitive to compatibility issues. The concerns about data
centers for land use compatibility typically pertain to surrounding residential uses. To this end, the City
may consider a setback requirement for data centers from properties guided by the Future Land Use
Plan for future residential use, residential zoning districts, existing residential uses or a combination
thereof. Requiring an increased setback serves to mitigate potential impacts of a data center.
An increased setback requirement for data centers from properties guided for residential land use,
residential zoning districts, or with existing residential uses may also be made reciprocal. A reciprocal
setback requirement would not allow a new residential use to be established within the setback area of
an existing data center. This preserves the desired separation between data centers and residential uses
long term ensuring that no new compatibility issues are created by residential uses encroaching close to
an existing data center.
The Future Land Use Plan includes areas guided for Industrial land use at the perimeter of the City
abutting the City of St. Michael, City of Albertville, and Monticello Township. Establishing a setback
requirement from properties guided, zoned, or used for residential purposes cannot be applied across
city boundaries as the City does not control the land use within the abutting jurisdiction. If there is a
concern of the Planning Commission as to potential impacts of a data center crossing over a City
boundary, a setback from a jurisdictional boundary may be considered for the same purpose of
mitigating potential noise, exterior lighting, and visual impacts.
Water Use. Data centers employ cooling systems to dissipate heat and maintain the facilities and
equipment at required temperatures. Use of water-based systems has potential for issues related to
surface waters, groundwater resources, utility system capacity, and water rates. Cooling may be
accomplished using either water- or air-based systems, although new alternatives are being developed
with the intent of reducing demand for water use. Mandating use of closed-loop water systems, for
example, can mitigate concerns regarding excessive water usage for data centers.
The development of a data center in Otsego would be subject to mandatory connection to City water
utilities as required by Section 8-1-3 of the City Code. The City water system operates under a permit
approved by the Minnesota Department of Natural Resources for appropriation of water. The aquifers
from which the City draws water are deep underground; water use from these aquifers does not
significantly affect water supplies for individual private wells. The City has adopted a Water System
Master Plan that guides the operation and expansion of the water utility system.
The Water System Master Plan estimates future water use based on growth forecasts and existing and
future land uses guided by the 2023 Otsego Comprehensive Plan. Water system improvements are not
funded by general City funds, such as property taxes, but by utility access and connection fees paid by
new development and user fees. Timing for improvements to the water system to add capacity or
expand the service area planned by the Water System Master Plan is coordinated with the Capital
Improvement Plan to estimate costs and allocate funding to ensure financial sustainability for the City
generally and system users who pay utility bills.
4

One of the criteria in Section 11-4-2.F of the Zoning Ordinance for considering an application for a
Conditional Use Permit is that “the proposed use can be accommodated by existing public services and
facilities and will not overburden the City's service capacity”. The City may establish a requirement that
a application for approval of a data center as a conditional use include water consumption plan to
outline water use requirements for the proposed use and impacts to municipal water supplies and
groundwater or surface water resources. This study would be evaluated by the City Engineer to
determine whether the City water system has capacity to accommodate the proposed use as well as
other planned development consistent with the 2023 Comprehensive Plan and Water System Master
Plan. If the City determines that there is not sufficient capacity available or planned to accommodate
the proposed data center, the City, at its discretion, may require the developer to fund the necessary
improvements or deny the Conditional Use Permit application.
Electric Service. There are three high-capacity electric transmission lines that bisect Otsego and
substations that could be used to serve data center uses. Proposals for the development of data centers
in other jurisdictions has brought forward concerns about costs for electric infrastructure and utility
rates.
Electric utilities are defined as essential services and regulation of electric utilities is largely beyond the
City’s jurisdiction, addressed at a State level by the Public Utilities Commission. The City is only allowed
to regulate electric overhead transmission lines and substations up to 100 kilovolts. Services less than 33
kilovolts are subject to administrative approval whereas facilities of more than 33 kilovolts and up to
100 kilovolts require approval of a conditional use permit in all zoning districts.
An application for development of a data center may require electric utility improvements that are
subject to City regulation in accordance with Chapter 32 of the Zoning Ordinance. The City may, as part
of a conditional use permit review process, require an electric consumption plan to be submitted to
identify electric service needs as represented by the utility provider and any improvements associated
with the proposed use. The need for additional transmission lines to provide service to a proposed data
center would also be required to be identified so that the new infrastructure can be evaluated
concurrent with the data center proposal.
Noise. Cooling systems utilized by data centers generate noise, which has been identified as a primary
concern for perceived impacts from data centers. The concern expressed relates not only to the sound
level, but also to the constant nature of the noise.
•

The City has adopted Minnesota Pollution Control Agency noise regulation rules as Section 1116-10 of the Zoning Ordinance as a general performance standard, which would apply to data
centers. The City may also consider data center specific standards such as the range of sound
regulated.

•

Noise mitigation can also relate to addressing water use concerns; cooling fans are the main
source of sound from data centers. Requiring closed-loop or alternatives to fans can mitigate
noise generation for data centers as well as minimize water use.

•

Setback requirements are also an effective means of noise mitigation as sound levels decrease
exponentially over horizontal distances.

5

The City may require, as part of the conditional use permit process, a noise study to be submitted that
details existing noise levels, outlines noise mitigation to be employed by the facility, and estimates postdevelopment noise levels. Cities have also used a requirement for a post-development sound study to
demonstrate the accuracy of the initial study estimates and effectiveness of the noise mitigation once
the facility is operational. The pre- and post-development noise studies are important for the City to be
able to determine compliance with established performance standards for noise generation either
generally or specific to data centers.
Screening. Data centers may have equipment or facilities that are not fully enclosed within a building.
The Zoning Ordinance includes general performance standards for required screening in Section 11-193. The performance standards for data centers as a conditional use may include requirements that any
equipment or facility not enclosed within a building must be screened using berms, landscaping,
fences/walls, or a combination thereof with minimum height and opacity requirements. Setback
requirements may also be used as a means of screening a data centers from view of major roadways
and surrounding uses. The Planning Commission has had extended discussions as to screening for recent
industrial development applications involving outdoor storage, such that consideration of screening
requirements for data centers may also serve as a basis for an update of general screening performance
standards for all commercial, office, and industrial uses within the City.
Exterior Lighting. The Zoning Ordinance establishes limits for exterior lighting in Section 11-16-6 of the
Zoning Ordinance. The City may consider developing exterior lighting performance standards for data
centers as a conditional use such as limiting the amount of blue light allowed, decreasing the maximum
intensity of allowed exterior lighting, or requiring that exterior lighting be reduced during overnight
hours. City staff would note that the current lighting standards of the Zoning Ordinance were adopted in
2002 before the advent of LED exterior lighting. City staff has noted concerns that the current Zoning
Ordinance standards do not adequately regulate LED lighting related to the list of potential issues above.
To this end, the Planning Commission may consider developing lighting standards for data centers as a
parallel effort to an update of the general performance standards of the Zoning Ordinance to be applied
to all commercial, office, and industrial uses.
Environmental Review. Minnesota Rules Chapter 4410 establishes requirements, procedures, and
criteria for environmental review for development. The purpose of environmental review is to evaluate
and understand the potential effects that a development will have on the environment. Environmental
review documents contain information that addresses the significant environmental issues of a
proposed development and is made available to governmental agencies and the public early in the
development review process. The environmental review process is intended to guide issuing, amending,
and denying development applications to avoid or minimize adverse environmental effects and to
restore and enhance environmental quality. Environmental review informs government decision-making
but does not itself approve or deny a proposed project.
Environmental review involves preparation of studies based on information requirements set forth by
Minnesota Rules. An Environmental Assessment Worksheet is a preliminary scoping document to
determine if a development has potential for significant environmental effects. The findings of an
Environmental Assessment Worksheet are used to determine if preparation of a more detailed and
comprehensive Environmental Impact Statement is to be required. Environmental review may also
follow a process known as Alternative Urban Area Review that addresses substantially the same issues
and follows the same process as the Environmental Assessment Worksheet and Environmental Impact
Statement. In most cases, the City serves as the Responsible Government Unit for reviewing the
environmental review and making findings as to potential for significant environmental effects.
6

Minnesota Rules 4410.1000 and 4410.2000 establish provisions for when a project requires preparation
of an Environmental Assessment Worksheet or an Environmental Impact Statement, respectively. There
is no specific requirement in Minnesota Rules for requiring environmental review for data centers,
which is a potential State-level regulatory topic. The most likely triggers for mandatory preparation of an
Environmental Assessment Worksheet or an Environmental Impact Statement are the conversion of
undeveloped land for industrial use based on acreage or construction of industrial building square
footage exceeding specified thresholds. The City may require preparation of an environmental review as
a discretionary action if it determines, at its discretion, that a proposed project may have the potential
for significant environmental effects. Minnesota Rules 4100.1100 also provides for a petition process
whereby any person may request the preparation of an Environmental Assessment Worksheet for a
project by filing a petition signed by at least 100 individuals who reside in or own property in the State,
although the Responsible Government Unit determines if the environmental review is to be required.
Implementation. The discussion provided by this memorandum serves as a general outline for
development of amendments to the Zoning Ordinance to address allowance and regulation of data
centers within the City. Immediate focus needs to be given to defining data center uses, determining the
zoning districts data centers and data center campuses are to be allowed in, and changing data centers
and data center campuses from permitted uses to conditional uses within the zoning districts the uses
are to be allowed in. A more concentrated effort will be needed to develop performance standards to
address perceived compatibility issues and impacts to City services and infrastructure.
Otsego is not the only government jurisdiction initiating a review of data center regulations. Cities and
counties (including Wright County) throughout Minnesota and nationally are undertaking similar efforts
either in anticipation of or in response to development proposals. There is also growing discussion as to
the need for State-level regulation of data centers, especially in terms of electric utility use and
environmental impacts. State level regulations would take longer to develop and implement as a
legislative process than a city may implement through zoning regulations.
Amendment of the Zoning Ordinance to ensure appropriate allowance and regulation needs to occur in
a timely manner to have provisions adopted prior to a data center being proposed in Otsego. However,
it would also be beneficial for the City, in developing its own regulations, to review and consider the
efforts of other government jurisdictions. Minnesota Statutes Section 462.355, Subd. 4 allows the City to
adopt an interim ordinance establishing a moratorium for the purpose of preparing development
regulations.
A moratorium may be established for a period of one year from the date of adoption. If amendments to
the Zoning Ordinance are complete before the end of the moratorium period, the moratorium can be
repealed. The Statute also provides that a moratorium can be extended if certain criteria are met.
Minnesota Statutes Section 462.355, Subd. 4 requires that the City Council conduct a public hearing to
consider the proposed interim ordinance. City staff requests that the Planning Commission make a
recommendation to the City Council as to establishment of a moratorium for data center uses to allow
for consideration of amendments to the Zoning Ordinance regulating such uses.

7

CONCLUSION
The Planning Commission will have an initial discussion of data centers and data center regulations at a
work session on 6 July 2026. The purpose of this work session is for questions and comments from the
Planning Commission about data centers and how the City may consider regulating this land use. City
staff requests the Planning Commission recommend whether the City Council should establish a
moratorium to allow further study without concern for an application being submitted that the City
would be required to react to.
c.

Adam Flaherty, City Administrator/Finance Director
Audra Etzel, City Clerk
Ron Wagner, City Engineer
David Kendall, City Attorney

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AMENDED: Res 2024-52, 22 Jul 24

ADOPTED: Res 2023-52,14 Aug 23

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FUTURE LAND USE PLAN

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DISCLAIMER:
This product is for informational purposes and may not have been
prepared for, or be suitable for legal, engineering, or surveying
purposes. Users of this information should review or consult the
primary data and information sources to ascertain the usability
of the information.

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COMPREHENSIVE PLAN 2023

ZONING PRACTICE

JUNE 2022

AMERICAN PLANNING ASSOCIATION

ISSUE NUMBER 6

PRACTICE DATA CENTERS

6

Zoning for Data Centers and
Cryptocurrency Mining
Data centers are the physical facilities where
the internet lives. Fundamentally, they consist of networked computer systems used
for data storage and processing, along with
supporting equipment, such as batteries,
back-up power generators, and cooling
devices. Modern data centers are the direct
descendants of the, so-called, telecom hotels
that began springing up in downtowns in the
late 1990s to accommodate the rapid expansion of the commercial internet and, before
that, of automated telephone exchange
facilities that made it possible to place landline telephone calls across a city, the nation,
or the world (Evans-Cowley 2002).
An emerging segment of the data center
market consists of facilities dedicated in
whole or part to “mining” cryptocurrency.
A cryptocurrency is a decentralized digital
currency that uses encrypted data strings to
denote individual units, or coins, and a peerto-peer database known as a blockchain to
maintain a secure ledger of transactions.
Several of the most popular cryptocurrencies, most notably Bitcoin, require extremely
complex computations to verify each transaction and add a record, or block, for that
transaction to the blockchain. Whoever
verifies a transaction first receives a new
cryptocurrency coin as a reward. While, theoretically, anyone with a computer server can
“mine” new coins by helping to verify these
transactions, large-scale cryptocurrency
mining requires a massive amount of computing power.
This article explores the reasons why
cities, towns, and counties may wish to
define and regulate data centers and cryptocurrency mining as distinct uses in their
zoning codes and provides a summary of
contemporary approaches. It begins with
a brief overview of the factors that drive
demand for data centers or cryptocurrency
mines in particular locations before examining the key planning issues that may merit
special attention through zoning and posing
a series of questions to guide code drafting.

Chad Davis / Flickr (CC BY 2.0)

By David Morley, aicp

A hyperscale Google data center in Council Bluffs, Iowa.

The article concludes with short profiles of
local zoning approaches that may serve as
models for others.
DEMAND DRIVERS
Industry analysts predict sustained growth
in data center construction in the coming
years (Dunbar and Bonar 2021). This includes
demand for larger and larger “hyperscale”
data centers as well as more widely distributed “edge” data centers (Sowry et al. 2018).
Data center developers (or operators) are
attracted to sites with low latency to end
users and dependable and affordable electricity.
While data centers have historically
been clustered around major internet access
points, information technology companies,
and government employment centers, the
proliferation of cloud computing and the
internet of things is pushing demand out
to network edges. This means more data
centers in smaller metropolitan and nonmetropolitan areas.
Big technology companies are likely to
continue looking for sites that can accommodate new, large single-story structures. But

operators that specialize in leasing space in
the same facility to multiple companies (i.e.,
collocated data centers) may be more open
to infill sites and existing structures, especially if those sites have access to fiber optic
infrastructure.
Data centers use a lot of electricity
(see below) to power processing and storage hardware and to keep that hardware
cool. The amount of electricity (and often
water) needed for cooling is higher in warm,
humid climates than in cool, dry areas.
Consequently, holding other factors equal,
developers favor locations with low electricity rates and cooler climates. Furthermore,
because these facilities operate continuously, developers are also looking for sites
that are less vulnerable to natural hazards.
Cryptocurrency miners are also looking for locations with cheap electricity and
low hazard risk; however, dedicated mining
facilities are not concerned about proximity to customers and are less likely to invest
in backup power. While there seems to be
a widespread consensus that data centers
are essential to global communications and
the global economy, cryptocurrency miners
ZONINGPRACTICE 6.22

AMERICAN PLANNING ASSOCIATION | page 2

PLANNING ISSUES
From the exterior, data centers and cryptocurrency mining facilities may be physically
indistinguishable from many commercial
or light industrial uses. However, the
operational characteristics of these facilities are typically quite distinct from those
of surrounding land uses. From a planning
perspective, the most noteworthy characteristics relate to their electricity and water use,
noise production, enhanced safety and security needs, and low employment densities.
They Use a Lot of Electricity (and Water)
In 2020, data centers used between 200
and 250 terawatt hours (TWh) of electricity,
accounting for approximately one percent
of global consumption (IEA 2021). While
the total consumption has grown steadily
along with global power demand, this ratio
has held relatively constant over the past
20 years as efficiency improvements have
proportionally offset increased demand
from data centers. However, this pattern
is unlikely to hold as growth in streaming
video, online gaming, cloud computing,
machine learning, virtual reality, and the
internet of things begins to outstrip efficiency improvements.
The figures above exclude cryptocurrency mining. Bitcoin miners alone used an
estimated additional 60 to 70 TWh in 2020.
According to Cambridge University, if Bitcoin
was country, it’s annual electricity consumption would be slightly higher than that of
Poland or Malaysia (2022).
Data center and cryptocurrency mining
equipment also generates a tremendous
amount of waste heat, which must be dissipated by fans or absorbed by a cooling
medium to avoid hardware damage and
ensure efficient operations. Many data centers and cryptocurrency mines use water as
a cooling medium. Water is also necessary
for most forms of electricity production. In
aggregate, a medium-sized data center typically uses more water each year than two
18-hole golf courses (Mytton 2021).

They Can Be Noisy
Inside a data center or cryptocurrency mine
server room, the noise can make it difficult to
carry on a conversation at a normal volume.
While most data centers and large cryptocurrency mines incorporate construction
and soundproofing techniques that ensure
this server noise isn’t audible outside of
the building, air conditioner compressors
mounted on the roof or on ground near these
facilities can generate noise that carries
across property lines.
In some contexts, vegetation or other
structures may rapidly attenuate this
sound. In others, the sound may travel over
long distances. Obviously, the degree to
which these sounds constitute nuisance
“noise” depends on surrounding land uses
and ambient noise levels. The problem is
typically most acute when data centers or
mines are near residences.
They Have Enhanced Safety and Security Needs
Data centers typically aim to run continuously, and any outage or downtime can
threaten business operations. Furthermore,
data centers house expensive, highly
specialized hardware, and many handle
sensitive data. Consequently, most data
centers incorporate enhanced safety and
security features, such as gated access
points, fencing, or bright lighting, to prevent
unauthorized access and to minimize the
likelihood of disruption.
Cryptocurrency mines have similar
safety and security needs, with two key
distinctions. First, miners want to maintain
network access, but the stakes are lower

than for data centers because an outage
wouldn’t negatively affect any other services
or users. Second, cryptocurrency mines generally aren’t receiving any clients and have
little incentive to draw attention to themselves with fencing or lighting.
They Have a Low Employment Density
Data centers typically have far fewer workers
per square foot than professional offices or
light industrial facilities (Tarczynska 2016).
And cryptocurrency mines generally have
even lower employment densities than data
centers. For some communities, data centers
(and potentially cryptocurrency mines) are
highly desirable from an economic development perspective because they often
generate a large property tax surplus that
can subsidize more service-intensive land
uses, such as single-family homes. Others,
however, are reluctant to devote too much
commercial or light industrial space to uses
that generate few jobs.
ZONING CONSIDERATIONS
Any community interested in regulating data
centers and cryptocurrency mining through
zoning should consider three key questions:
1. Do these uses need new use definitions?
2. Where should these uses be permitted?
3. Do these uses need special development
or performance standards?
Do They Need New Use Definitions?
New land uses don’t necessarily require new
use definitions in the local zoning code. It
depends, in part, on whether the use fits

ebayink / Flickr (CC BY-NC-ND 2.0)

have a more limited “social license” to operate. Widespread concerns about the energy
use of mines and the limited utility of the
coins they produce has led some countries,
including China, to ban Bitcoin mining. Consequently, many cryptocurrency miners are
relocating to the U.S. (Obando 2022).

The roof of eBay’s Topaz data center in South Jordan, Utah.

ZONINGPRACTICE 6.22

AMERICAN PLANNING ASSOCIATION | page 3

neatly under a broader use category or is
substantially like another defined use. And
it depends on whether treating the new use
the same as this use category or other similar use would be likely to generate negative
effects on nearby properties or the community as a whole.
Many communities have defined data
centers (or some closely analogous term) as
a distinct use in their zoning codes. These
definitions typically reference the general
function of the facility and the degree to
which it is occupied by computer systems
and related equipment. For example, Anne
Arundel County, Maryland, defines data storage center as “a facility used primarily for
the storage, management, processing, and
transmission of digital data, which houses
computer or network equipment, systems,
servers, appliances, and other associated
components related to digital data storage
and operations” (§18-1-101.(44)).
Comparatively fewer communities have
defined cryptocurrency mining as a distinct
use. Many of these definitions focus on the
specialized purpose of the facility, often with
references to other newly defined terms,
such as high density load or server farm,
that clarify its distinct characteristics. For
example, Moses Lake, Washington, specifies
that cryptocurrency mining often uses more
than 250 kilowatt-hours per square foot each
year (§18.03.040).
Where Should They Be Permitted?
Communities that choose to regulate data
centers or cryptocurrency mines as distinct
uses may permit these uses either by right
or with a discretionary use permit (i.e.,
conditional, special, or special exception
use permits) in one or more existing base or
overlay zoning districts. Alternatively, they
may elect to establish a new special-purpose
base or overlay zoning district for either use.
Many communities permit data centers
and cryptocurrency mines either by right
or with a discretionary use permit in commercial and industrial districts. While data
centers and mines can fit in a wide range of
existing commercial or industrial buildings,
purpose-built facilities are often single-story
structures with large floorplates.
Given that they generally have few
employees and visitors, these uses may
not be appropriate in ground-floor streetfrontage spaces in pedestrian-oriented

EXAMPLES OF DEFINED USES
Jurisdiction

Defined Uses

Alpharetta, GA

Data center (§1.4.2)

Anne Arundel County, MD

Data storage center (§18-1-101.(44))

Fairfax County, VA

Data center (§9103)

Frederick County, MD

Critical digital infrastructure facility (§1-19-11.100)

Moses Lake, WA

Cryptocurrency mining; Data center/server farm/cluster
(§18.03.040)

Pitt County, NC

Data processing facility (large scale) (§15)

Plattsburgh, NY

Commercial cryptocurrency mining; Server farm; High
density load service (LL 6-2018)

Prince George’s County, MD

Qualified data center (§27-2500)

Prince William County, VA

Data center (§32-100)

Somerville, MA

Data center (§9.8.b)

Vernal, UT

Data center (§16.04.173)

Wenatchee, WA

Cryptocurrency mining; Data center (§10.08)

commercial areas. Wenatchee, Washington,
addresses this issue by permitting data
centers and cryptocurrency mines by right
in multiple pedestrian-oriented commercial
districts, with a simple stipulation that they
cannot occupy “grade level commercial
street frontage” (§10.10.020).
A new special-purpose zoning district
can help steer data centers or cryptocurrency
mines toward corridors or other subareas
that have suitable utility infrastructure.
When adopted as floating zones, special
districts can also provide an extra layer of
review for large projects that may cover dozens or hundreds of acres.
Prince William County, Virginia, added
a Data Center Opportunity Zone Overlay District to its zoning code in 2016 (§32-509). The
county has mapped this overlay to more than
70 percent of its industrially zoned land. The
overlay permits data centers and includes
design standards for these facilities; however,
it does not otherwise modify the existing use
permissions for underlying districts.
Do They Need Special Development or
Performance Standards?
Communities that decide to regulate data
centers or cryptocurrency mines as distinct
uses may choose to adopt use-specific
standards that modify or supplement other
relevant universal or district-specific development or performance standards. This
approach can help communities target standards to the distinct features of these uses

to address specific community concerns.
Use-specific standards can help minimize reliance on discretionary approvals and
improve the consistency of local decisions.
Without these standards, local officials may
be more likely to require all data centers and
cryptocurrency mines to obtain a discretionary use permit, and they may be more likely
to adopt wildly varying conditions of approval
for substantially similar proposals.
Communities that have adopted usespecific standards for data centers and
cryptocurrency mines often establish building
design and buffering or screening requirements to minimize the visibility or improve
the appearance of these facilities from public
streets or nearby properties. Other common
standards address environmental performance, including noise and light pollution,
and evidence of electric utility approval.
POTENTIAL MODEL APPROACHES
It would be difficult to find a community with
more experience with data centers than
Loudon County, Virginia. And the county’s
approach to zoning for data centers serves as
a potential model for other communities with
suitable sites and sufficient infrastructure to
accommodate data center development. In
contrast, Missoula County, Montana, was one
of the first local jurisdictions to craft zoning
regulations for cryptocurrency mining operations. And its emphasis on mitigating the
potential climate impacts represents a different type of potential model.
ZONINGPRACTICE 6.22

AMERICAN PLANNING ASSOCIATION | page 4

Loudon County, Virginia
Northern Virginia’s Data Center Alley, primarily clustered around Routes 7 and 267
in Loudon and Fairfax Counties is the largest data center market in the world (Fray
and Koutsaris 2022). Its combined power
consumption capacity is more than 1.6 gigawatts (GW), nearly twice as much as the next
largest market. And within Data Center Alley,
Loudon County has the highest concentration of data centers. As of October 2021,
data centers occupied more than 25 million
square feet, with another 4 million square
feet in development (LCDED 2022).
Several important factors have driven
demand for data center development in
Loudon County. It is home to the Equinix
internet exchange, one of the largest internet
access points in the world and a successor to
Metropolitan Area Exchange, East, the first

U.S. exchange. The county has abundant
(and redundant) fiber optic infrastructure,
relatively cheap power, and sufficient water.
Additionally, it has a high concentration of
skilled technology workers and businesses
that support the data center industry.
By the year 2000, there was already
an emerging data center cluster in Loudon
County. However, the county did not define
and regulate data centers as a distinct use
in its zoning code until 2014 (ZOAM 20130003). According to Acting Planning & Zoning
Director James David, prior to this, the county
defined data centers as commercial offices.
The latest version of the county’s
zoning ordinance permits data centers by
right in Planned Office Park, Research and
Development Park, Industrial Park, and
General Industrial districts and as a special
exception use in Commercial Light Industry

districts. New data centers (without vested
rights) must comply with a set of use-specific
standards governing façade design, screening of mechanical equipment, exterior
lighting, pedestrian and bicycle facilities,
and landscaping, buffering, and screening
(§5-664).
According to David, these standards
are intended to improve the aesthetics of
data centers, minimize visibility from nearby
residential areas, and ensure continuous
sidewalk and trail networks. Overall, they
represent a light-touch approach that has,
so far, worked well for a county with enormous demand for data centers and relatively
modest competition for space from other
commercial and industrial uses.
However, in February 2022, county
officials directed staff to research regulatory
options to prevent new data centers in the

EXAMPLES OF USE-SPECIFIC STANDARDS FOR DATA CENTERS AND CRYPTOCURRENCY MINING
Jurisdiction

Use-Specific Standards

Alpharetta, GA

Requires evidence of compliance with noise standards; specifies exterior lighting fixture design; establishes
minimum building height; requires building façade design elements; establishes other fencing, screening, and
landscaping requirements to minimize visibility from adjacent roads and properties (§2.7.2.1)

Anne Arundel County, MD

Establishes minimum lot size and setbacks; prohibits residences on the same lot; establishes limit on outdoor
storage (§18-10-119)

Fairfax County, VA

Requires all equipment to be enclosed within a building; establishes maximum floor area by zoning district
(§4102.6.A)

Frederick County, MD

Establishes criteria for reducing setbacks; specifies building design standards; specifies landscaping,
screening, and buffering requirements; clarifies parking, loading, signage, and lighting standards; establishes
criteria for private roads; establishes noise and vibration standards (§1-19-8.402)

Moses Lake, WA

Clarifies review process for business license; prohibits container storage; requires evidence of electrical
utility approval; requires evidence of electrical permit and inspection; establishes environmental performance
standards, addressing noise, heat, and electric and magnetic fields; limits amount of exposed equipment on
facades (§18.74)

Pitt County, NC

Limits height; requires separation from sensitive uses; requires noise study and compliance with noise
standards; requires underground wiring; requires security fencing and vegetative screening; requires evidence
of electrical utility approval; clarifies signage standards; requires notification of abandonment (§8(UUUU))

Plattsburgh, NY

Requires fire suppression and mitigation techniques; limits internal ambient temperature and the direct
release of heat on colder days; establishes permissible noise levels (LL 6-2018)

Prince George’s County, VA

Requires building façade design elements; specifies exterior lighting fixture design; requires screening for
security fencing and limits fence height; requires compliance with landscape manual; clarifies applicable offstreet parking standard; clarifies signage standards; requires an acoustical study; specifies additional site,
locational, and noticing requirements for facilities in rural residential districts (§27-5102(e)(4)(B))

Somerville, MA

Establishes special review criteria related to aesthetic impacts and employment opportunities (§9.8.b)

Vernal, UT

Requires fencing and structural screening for electrical generators; requires noise mitigation plan for facilities
near residential zones or existing hotels or motels (§16.20.250)

Wenatchee, WA

Clarifies review process for business license; prohibits container storage; requires evidence of electrical utility
approval; requires evidence of electrical permit and inspection; clarifies blank wall limitation standards;
requires an affidavit verifying operating sound levels (§18.48.310)

ZONINGPRACTICE 6.22

AMERICAN PLANNING ASSOCIATION | page 5

Missoula County, Montana
In April 2019, Missoula County, Montana,
adopted an interim zoning resolution that
established a cryptocurrency mining overlay
(Resolution No. 2019-026). The county had
one large cryptocurrency mine already, and
its low electricity rates and cool climate
made it an attractive area for prospective
miners. While a few other jurisdictions had
already defined cryptocurrency mining in
their zoning codes, Missoula County appears
to be the first to explicitly position its zoning
approach as a response to climate change.
According to county planner Jennie
Dixon, aicp, local officials originally took an
interest in regulating cryptocurrency mining
as a distinct use after multiple complaints of
noise from cooling fans at an existing Bitcoin
mine operating out of a former sawmill in
unincorporated Bonner. Soon, though, the
county expanded its focus to include energy
consumption and electronic waste.
Montana law only authorizes interim
zoning in the case of an emergency involving
“public health, safety, morals, or general
welfare” (§76-2-206). Dixon says the Intergovernmental Panel on Climate Change’s
2018 Special Report on Global Warming of
1.5° C helped justify climate change as a
local emergency that warranted interim zoning to mitigate greenhouse gas emissions
(and other potential environmental impacts)
from cryptocurrency mining.
The interim zoning regulations defined
cryptocurrency mining as a distinct use and
created a Cryptocurrency Mining Overlay
Zone, mapped to the entire unincorporated
geographic extent of the county (which
includes some un-zoned areas). The overlay

Google Earth

The heart of Northern Virginia’s Data Center Alley in Ashburn, Virginia.

Google Earth

Route 7 corridor. While data center demand
remains high in this area, the county’s
comprehensive plan designates most of
this corridor as Suburban Mixed Use, which
envisions a compact, pedestrian-friendly
mix of commercial, residential, cultural, and
recreational uses. Furthermore, the existing
electricity network infrastructure is insufficient to accommodate the existing demand
for new data centers (LCDED 2022).
The county is working on its first complete overhaul of its zoning code since 1993.
And it intends to incorporate any new regulations for data centers into the new code,
which officials hope to adopt by the end
of 2022.

The former Bonner sawmill in Missoula County, Montana, was once
home to the HyperBlock cryptocurrency mine.

restricted cryptocurrency mining operations to industrial districts and required
operators to obtain a discretionary use permit if the mine was adjacent to a residential
district or within 500 feet of a residential
property boundary. These regulations
also required all mining operations to
verify that all electronic waste be handled
by a licensed recycling firm and that all
electricity use be offset by new renewable
energy production.
Caroline Lauer, the county’s Sustainability Program Manager, stresses the
importance of this last requirement. If
cryptocurrency miners purchased existing
supplies of renewable energy, it could actually displace existing utility customers to
dirtier sources. While most of the county’s

electricity comes from hydropower, coal
accounts for much of the remainder.
Missoula County’s 2016 Growth Policy
plan includes an objective to “reduce the
county’s contribution to climate change”
(4.1) and lists policies that promote alternative energy development (4.1.3) and reduce
energy use and waste generation as implementation actions (4.1.6). A day before it
adopted the interim cryptocurrency mining
regulations, the county further strengthened
its policy rationale by adopting a joint commitment with the City of Missoula to achieve
100 percent clean electricity use by 2030.
County officials extended the interim
zoning for another year in 2020 before adopting the same regulations as a permanent
zoning amendment in March 2021 (§1.04
ZONINGPRACTICE 6.22

AMERICAN PLANNING ASSOCIATION | page 6

& §5.05). According to Dixon, the Bonner
mine ceased operations during the interim
zoning period, but not because of the
county’s zoning. It declared bankruptcy
two days after the “Black Thursday” Bitcoin
crash in March 2020, leaving the tribalowned independent power producer that
provided its electricity with a $3.7 million
unpaid bill (Rozen 2020).
CONCLUSIONS
The rapid rise in data center development
has coincided with dramatic decreases in
the costs of producing solar and wind power.
This, in combination with a growing trend
toward clean power commitments among
technology companies, has blunted some of

REFERENCES AND RESOURCES
Dunbar, Courtney and Robert Bonar.
2021. “Siting Next-Generation Data
Centers.” Area Development, Q2.
bit.ly/390dyJ3
Evans-Cowley, Jennifer. 2002. Telecom
Hotels: A Planners Guide. PAS Report
No. 505. Chicago: American Planning
Association. bit.ly/39Dezaa
Fray, Andrew and Bobby Koutsaris.
2022. 2022 Global Data Center Market
Comparison. Chicago: Cushman &
Wakefield. cushwk.co/3P8JOdB
Gomez, Alexsandra and Joseph
DeAngelis. 2022. Digitalization and
Implications for Planning. Chicago:
American Planning Association.
bit.ly/3KUP1lT
International Energy Agency (IEA). 2021.
“Data Centres and Data Transmission
Networks.” Tracking Report, November.
bit.ly/3FsMSwR
Loudon County [Virginia] Department of
Economic Development (LDED). 2022.
Loudon County Data Center Land Study.
bit.ly/3P7DYt0
Missoula (Montana), County of. 2021.
“Cryptocurrency Mining.” bit.ly/3PbSr72

the climate impacts of an increased demand
for data storage and processing.
The increased digitalization of life
virtually guarantees that data centers will
continue proliferating in strategic locations
across the country (Gomez and DeAngelis
2022). Soon, communities may start seeing a
sharp increase in interest in very small edge
data centers that could fit in underutilized
commercial spaces or even be collocated
with other telecommunications infrastructure, such as small cell facilities, in public
rights-of-way (Sowry et al. 2018).
The future of cryptocurrency mining
facilities is less certain. Bitcoin and other
energy-intensive cryptocurrencies are facing social pressure to transition to more

Mytton, David. 2021. “Data Centre Water
Consumption.” NPJ Clean Water, 4(11).
bit.ly/3wjRUaR
Obando, Sebastian. 2022.
“Cryptocurrency Bans Fuel US Data
Center Construction.” Construction Dive,
February 16. bit.ly/3w7aG6t
Rozen, Jacob. 2020. “Poor Business
Model, Not COVID-19 Behind Hyperblock
Early Struggles.” Coingeek, December
23. bit.ly/37uFHYp
Tarczynska, Kasia. 2016. Money Lost to
the Cloud: How Data Centers Benefit From
State and Local Government Subsidies.
Washington, D.C.: Good Jobs First.
bit.ly/398mn3m
Sowry, David, Jani Dharmesh, Don
Duet, Frank Yan, Harry Smeenk,
James Young, Phillip Marangella, and
Robert Bunger. 2018. TIA Position
Paper: Edge Data Centers. Arlington,
Virginia: Telecommunications Industry
Association. bit.ly/3N3U58Y
University of Cambridge. 2022.
“Cambridge Bitcoin Electricity
Consumption Index.” bit.ly/38hj1v1

energy-efficient transaction verification
methods, and several existing cryptocurrencies already use these methods. However,
we are still at the very beginning of the cryptocurrency story. While this form of currency
currently exists primarily as a speculative
investment vehicle, this could change rapidly
if valuations stabilize and large numbers of
goods and service providers accept cryptocurrencies for payment.
Not every community will see the value
in defining data centers or cryptocurrency
mines as distinct uses in their zoning codes.
Nevertheless, doing so can give local jurisdictions a leg up when it comes to signaling
preferences to developers and operators
and minimizing or mitigating potential
adverse impacts.

ABOUT THE AUTHOR
David Morley, aicp, is a research program
and QA manager with the American Planning
Association and editor of Zoning Practice.

Cover: iStock.com/gorodenkoff

VOL. 39, NO. 6
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ZONINGPRACTICE 6.22

AMERICAN PLANNING ASSOCIATION | page 7

HOW DOES YOUR ZONING
TREAT DATA CENTERS AND
CRYPTOCURRENCY MINES?

6

205 N. Michigan Ave.
Suite 1200
Chicago, IL 60601–5927

AMERICAN PLANNING ASSOCIATION

ZONING PRACTICE

Creating Great Communities for All

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?

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

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

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)?

1,410.3 ≈ 9.4
Golf Courses
1,108.3 ≈ 7.4
Golf Courses
853.8 ≈ 5.7
Golf Courses

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.

532.3 ≈ 3.5
Golf Courses

461.1 ≈ 3.1
Golf Courses

400
200
0
Council Bluffs, Mayes County,
Berkeley
Papillion, NE The Dalles, OR
IA
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

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

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

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

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

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

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

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

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,
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