The Tool Desk
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Start by checking what the restriction actually covers
A moratorium may pause applications temporarily while officials develop permanent standards; a zoning amendment may impose lasting limits. Before comparing sites, confirm the measure’s legal status and scope: whether it is enacted or proposed, which applications and facilities it covers, when it takes effect, and whether it has been extended, replaced, or expired.
Definitions matter. A local rule may distinguish facilities by floor area, power capacity, principal use, or campus configuration. For example, Madison’s moratorium applies to new principal-use data centers larger than 10,000 square feet, while Seattle’s council bill defines covered large-scale facilities using a capacity threshold above 20 MVA. Those are local definitions, not general thresholds that apply elsewhere. See Madison’s data-center planning page and Seattle Council Bill 121214.
Alternatives to investigate
Reuse an existing building
Some policies may allow data-center use in an existing building even when new construction is restricted. Minneapolis’s preliminary recommendations say new data centers would need to be placed in existing buildings when its proposed ordinance takes effect; Madison describes smaller facilities as typically tenants in existing buildings. These are not blanket permissions. A reused building may still need to meet zoning, use, building-safety, utility, and permitting requirements, and Minneapolis’s recommendations are preliminary. Minneapolis’s data-center page and Madison’s planning page describe their local approaches.
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A smaller facility may fall outside a rule aimed at large, principal-use data centers, but only if the local text makes that distinction. Madison’s page describes small centers below 10,000 square feet as often occupying existing buildings, alongside proposed size-based zoning treatment. Other jurisdictions may define or regulate smaller facilities differently; do not assume that reducing floor area makes a project exempt.
Check whether an existing facility can expand
Expansion rights depend on explicit exceptions. Seattle’s council bill includes a limited exception under which certain facilities already operating when the ordinance takes effect may qualify to expand by no more than an additional 20 MVA, subject to the bill’s conditions. Oklahoma City’s moratorium, by contrast, pauses permits related to construction or expansion, while exempting two pending rezoning cases. Read the controlling, current text rather than inferring that an existing site can grow.
Investigate a parcel outside the city
A project outside the restricting city may fall under a different government’s rules, but crossing a boundary is not approval. Tulare County’s interim moratorium applies to new development in unincorporated county areas, not within its eight incorporated cities. For any candidate parcel, identify the authority that controls zoning and permits, then check county, state, utility, environmental, and other applicable approvals. Tulare County reported that its board was scheduled to consider extending the moratorium on September 22, 2026; the county page cited here does not report the meeting’s result, so its current status needs confirmation. Tulare County’s planning page.
Adapt the proposal or wait for permanent standards
A pause can give a developer time to revise a site plan or wait for rules that clarify what is allowed. Oklahoma City said its moratorium was intended to let the council assess energy use, water demand, and land use before deciding on a regulatory framework. Seattle’s bill describes a 365-day moratorium to allow consideration of permanent legislation. Those stated purposes do not guarantee that a later rule will permit a project, and a time-limited pause can be followed by a surge of applications when it lifts. The Urban Institute discusses that risk in its analysis of local moratoria.
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Compare candidate sites and project designs
Use the same checklist for each location; a promising building or parcel is only a lead until the relevant authorities and service providers confirm the requirements.
- Jurisdiction and rule status: Identify who controls the parcel and whether the restriction is adopted, proposed, temporary, extended, expired, or replaced. A draft recommendation is not adopted zoning.
- Facility definition and scale: Check whether the rule turns on floor area, power capacity, principal use, campus configuration, or another definition.
- Building and land-use fit: Establish whether existing-building reuse is permitted, which zones allow the use, what buffers or neighboring-use rules apply, and whether the data center would be a principal use or support another primary use.
- Power and water: Review electricity demand, utility coordination, water supply, cooling systems, and supporting infrastructure. Minneapolis’s preliminary application requirements call for expected water and electricity disclosures and evidence of coordination with the electric utility; Tulare County lists water, cooling, electricity demand, and infrastructure among review subjects.
- Noise, environmental, and safety impacts: Find out what the jurisdiction requires for noise, lighting, air quality, backup power, batteries, fuel storage, fire protection, emergency response, and transportation. Requirements vary by location.
- Community and economic outcomes: Consider accountability, public engagement, revenue, utility costs, infrastructure, jobs, and public land. The Urban Institute recommends evaluating these factors in light of local residents’ and economies’ needs.
Examples are local, and their status can change
Local measures illustrate possible approaches, not a universal menu of legal options. The Urban Institute reported that 313 moratoria had been enacted as of September 2026, affecting 44 states and more than 200 cities, counties, and other localities. That count appears in its September 11, 2026 article and links to an underlying tracker; it is not a count of currently active restrictions. Urban Institute’s article on data-center moratoria.
Quick Recap
- Oklahoma City: The city announced on April 21, 2026, that its council approved a temporary moratorium halting new applications, rezoning requests, and permits for data-center construction or expansion. The city said it would remain until December 31, 2026, or earlier if data-center zoning amendments were approved, and it exempted two pending rezoning cases. Confirm whether the city has changed the rules since that announcement. Oklahoma City’s announcement.
- Minneapolis: The city describes a temporary pause in most of the city and preliminary recommendations that include existing-building placement, conditional-use review, size limits, utility coordination, and water and power disclosures. The page identifies the recommendations as preliminary and lists additional review dates; check the latest council action before treating them as final rules. Minneapolis’s data-center page.
- Madison: The city says its Common Council approved a temporary moratorium on January 13, 2026, covering new principal-use data centers larger than 10,000 square feet. Its page describes proposed size-based rules and zones, but reported on September 29 that no final action had been taken on the framework recommendations. Recheck for later action. Madison’s data-center page.
- Seattle: Council Bill 121214 sets out a one-year, 365-day moratorium on covered applications and says the city intends to consider permanent legislation during the pause. It includes a limited exception for a qualifying existing operating facility seeking an expansion of no more than an additional 20 MVA. Verify the bill’s enactment and effective date before calculating a current deadline. Seattle Council Bill 121214.
- Tulare County: The county page reports that an interim ordinance adopted August 18, 2026, established a 45-day moratorium in unincorporated county territory, with an extension scheduled for board consideration on September 22. The page cited here does not give the meeting’s outcome; do not rely on the moratorium’s continued status without checking. Tulare County’s planning page.
How to make the next decision
- Pin down the parcel and the government that has authority over its zoning and permits.
- Get the current ordinance or moratorium text, including amendments, effective dates, exceptions, and any sunset or extension.
- Match the proposed facility’s size, capacity, use, and site configuration to the rule’s definitions.
- Ask planning officials and relevant utilities what approvals, service coordination, and impact disclosures the specific proposal would require.
- Compare the compliant options—reuse, smaller scale, eligible expansion, another jurisdiction, redesign, or waiting—without treating any one as a guaranteed path to approval.
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