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What information should you get about the proposal first?
Ask for the current application and supporting technical documents. A verbal description or headline capacity figure is not enough to evaluate local effects. Establish exactly what is proposed, what is included in the project boundary, and what may be built in later phases.
- Site and schedule: property boundary, total area, phased development, construction schedule, access routes, and associated utility corridors or substations.
- Facility design: expected scale, cooling technology, water systems, anticipated electricity demand and its daily or seasonal profile.
- Energy arrangements: proposed electricity source and delivery path, grid or utility upgrades, onsite generation, and backup generators, including expected operating and testing assumptions.
- Water and wastewater: source, seasonal and peak demand, wastewater destination and treatment, and any proposed use of reclaimed water.
- Supporting approvals: permit applications, environmental studies, utility plans, traffic analyses, and proposed mitigation or monitoring commitments.
Check whether documents describe the same project version. If the design, phasing, utility service, or cooling plan has changed, request updated analyses rather than assuming earlier findings still apply.
What baseline and study area are needed?
A baseline describes existing conditions against which project-related change can be assessed. It should fit the site and the pathways through which effects could occur: a water analysis may need to cover a watershed or aquifer, while noise analysis should identify nearby sound-sensitive locations. Ask which area each study covers and why that boundary is appropriate.
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EPA environmental-impact review guidance identifies resource areas to consider, including local ambient air; surface- and groundwater quantity and quality; ecology and protected areas; population and nearby receptors; land use; energy supply and demand; ambient noise; cultural resources; and the regulatory setting. The project team should analyze likely affected resources in detail and explain or reference those it considers unlikely to be affected.
Look for observations or records that capture conditions when effects could be greatest—for example, seasonal water stress, peak demand, construction activity, or nighttime noise. Ask for the data source, date, location, measurement method, and any important gaps. A general regional description may not establish conditions at nearby homes, waterways, or other sensitive locations.
How should water use be evaluated?
Keep three quantities separate: withdrawal is water taken from a source; consumption is water not returned to the same water system, often because it evaporates; and discharge is water returned, potentially after treatment. Ask for each quantity, its calculation period, source, destination, and seasonal or peak value. Also distinguish direct onsite water from indirect water associated with electricity generation. A facility figure may omit that indirect component.
Penn State Extension’s October 20, 2025 article, “Data Centers and Water Use in Pennsylvania,” explains that facility-specific figures can be difficult to establish: reporting may not be required, electricity-use data may not be publicly available, water demand varies with location and energy source, and published figures may omit indirect water use. Treat every number as a claim with a boundary and method, not as a complete account by default.
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The following examples are direct facility water figures for 2024 summarized by Penn State Extension in 2025. They exclude indirect water use and are not estimates for other facilities.
| Google data center location | Withdrawn in 2024 | Consumed in 2024 | Discharged in 2024 |
|---|---|---|---|
| Ashburn, Virginia | 59.5 million gallons | 56.0 million gallons | 3.5 million gallons |
| Bristow, Virginia | 105.7 million gallons | 84.4 million gallons | 21.3 million gallons |
| Sterling, Virginia | 201.2 million gallons | 158.2 million gallons | 43.0 million gallons |
| New Albany, Ohio | 405.3 million gallons | 352.7 million gallons | 52.6 million gallons |
Ask whether the stated source is municipal supply, groundwater, reclaimed water, or another source, and how demand could affect other users and receiving waters during dry or high-demand periods. Review the wastewater route and treatment, not only the volume used onsite.
Water-use effectiveness (WUE) is onsite water consumption divided by data-equipment energy over a specified period. It can help compare efficiency, but it does not measure local water scarcity or total indirect water use. Compare WUE values only when units, system boundary, and calculation method match.
What should you check about electricity and air emissions?
Request the expected electricity load and demand profile, how power will be delivered, and any planned grid or utility upgrades. Where onsite generation is proposed, ask what equipment will run routinely, what is reserved for emergencies or testing, and how often, for how long, and under what conditions it is expected to operate.
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Review relevant air-permit applications and modeling for the proposed equipment. Check which pollutants and operating scenarios were modeled, where concentrations were predicted, and how the results relate to nearby residents and habitats. Routine operations and emergency or testing operations should not be blurred into one assumption. EPA’s data-center air resources describe modeling inputs and professional judgment as case-specific; ask the project team to identify its inputs, methods, assumptions, uncertainty, and affected receptors.
On July 27, 2026, EPA announced that its guidance clarifies that the Clean Air Act Acid Rain Program does not apply to power-generation facilities that are not connected to a public electricity grid (“islanded” generation). This is a specific permitting detail, not a general exemption from other air requirements. Confirm the actual project’s current permit record and applicable regulations rather than inferring its outcome from that clarification.
Which land, noise, ecology, and community effects matter?
Check the site plan against zoning, adopted land-use plans, and neighboring existing or planned uses. Consider the footprint of the facility as well as substations, access roads, transmission connections, pipelines, and other utility infrastructure. Ask whether the project could induce nearby development or extend effects beyond the parcel.
For noise, request baseline measurements and estimates for both construction and continuous operations at sensitive receptors such as homes, schools, and hospitals. The analysis should state where and when measurements were taken, what sources were included, and which operating conditions it assumed.
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Depending on the site, examine stormwater and erosion controls, floodplains, wetlands, groundwater and surface water, habitat and protected species, traffic, public services, and cultural resources. Determine whether utility corridors or construction routes add effects not captured by a facility-only study. EPA review guidance recommends focusing detailed analysis on components likely to be affected rather than treating every resource category identically.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How can you compare alternatives and cumulative effects?
Compare feasible site and design alternatives using the same boundaries, assumptions, and time periods. Where applicable, include a no-action alternative. Ask why the preferred option meets the project’s purpose and what trade-offs led to its selection; an alternative analysis is not useful if it compares different options using inconsistent methods.
For each alternative, examine these common decision points:
- Water withdrawal, consumption, discharge, source, and effects on other users.
- Energy demand, source and delivery, onsite generation, and associated local air emissions.
- Land and habitat disturbance, noise at nearby receptors, and consistency with local plans.
- Infrastructure capacity and costs, including shared utility systems and corridors.
- Construction, operation, and closure where relevant, plus cumulative effects of nearby development.
- Uncertainty, monitoring, and the feasibility and effectiveness of proposed mitigation.
Do not assess the facility as an isolated parcel if it depends on shared infrastructure or would operate alongside other development. Ask whether the analysis accounts for combined demand on water, power, roads, public services, and the environment, and whether it explains the geographic and time boundaries used for cumulative effects.
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How do you judge the evidence and proposed mitigation?
For each important conclusion, ask the proponent to show the underlying data, method, model, assumptions, and uncertainty. Look for a clear connection between a predicted effect, the people or resources that could experience it, and the measure proposed to prevent or reduce it. Seek independent technical review when evaluating models or assumptions requires expertise not available to the public or decision-makers.
A mitigation commitment is easier to evaluate when it has a measurable baseline, a stated performance target, a monitoring method and schedule, and a response if results fall short. Ask who will collect and report the data, who can review it, and whether the commitment continues through the relevant project phase. A promise to “minimize” an effect without a measurable outcome is difficult to verify.
Which rules and review process apply?
Identify the agencies with authority over the actual proposal, the permits or approvals required, applicable current standards, and public comment opportunities. These depend on project design and jurisdiction; a general checklist cannot establish compliance or determine whether a particular impact is legally significant.
Federal NEPA procedures apply when there is a qualifying federal action, not automatically to every locally proposed data center. Under the U.S. Department of Energy’s process, an environmental assessment (EA) considers alternatives and foreseeable effects; DOE prepares an environmental impact statement (EIS) when it determines that a proposed agency action will have a reasonably foreseeable significant effect. Do not assume DOE review applies without a federal action or treat a local approval process as a federal NEPA review.
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Without a specific site, design, jurisdiction, permit record, and supporting data, no generic guide can determine the environmental significance of a particular proposal. The useful outcome of an evaluation is a traceable account of what is known, what remains uncertain, and how effects will be avoided, reduced, or monitored.
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