Data centers generate massive amounts of heat and need millions of gallons of water annually for cooling. Training AI models can consume hundreds of thousands of liters of water, and even everyday AI queries add up. These facilities also need permits for air emissions (from backup diesel generators), stormwater management, and impacts on wetlands. Some federal and state environmental laws require review processes that developers can’t skip.
Environmental reviews under federal and state law create protected public participation opportunities. Agencies must respond to substantive comments, and weak environmental analysis can be challenged through appeals and lawsuits. The scientific evidence on AI’s water and energy consumption is growing rapidly and communities can provides concrete data to cite when demanding comprehensive Environmental Impact Statements instead of cursory reviews.
Most water issues are addressed at regional, state, or local levels. In general, the federal government sets standards for the amount of pollution allowed in water discharges (“point sources”) and site run-off (“non-point sources”) which are implemented by the states. Access to water from a lake, reservoir, or aquifer is based on water law, which is quite different in the generally wet eastern US and the often arid western United States.
This gateway matters because developers want quick approvals with minimal conditions and limited public disclosure. Communities can file detailed scoping comments demanding thorough review, present expert testimony from hydrologists and scientists, challenge chemical risks from cooling systems, and organize environmental justice coalitions to document cumulative impacts. When EPA regional offices, state environmental agencies, and water authorities see organized community opposition backed by scientific evidence, they’re normally forced to take a harder look.
Key Targets (Gatekeepers)
- Environmental regulatory agencies: EPA regional offices and state DEP officials
- Water resource managers: State and local water authorities managing supply and rights
- Environmental impact reviewers: Agency staff conducting NEPA/SEPA/CEQA reviews, Federal and State
- Wetlands and watershed protection boards: Local authorities managing water quality and ecosystems
- Environmental organizations: Respected or widely known groups who mobilize others around environmental concerns
- Outdoor recreation organizations: Groups like fisherman and birders who enjoy access to healthy rivers and streams
- Farmers and agricultural organizations: farmers need clean water
Possible Interventions
- Mandate Advanced Water Management: Require liquid cooling systems, waste heat recycling, and closed-loop systems. Demand proof of water efficiency measures that reduce consumption by 80%+ compared to traditional cooling
- Technical Water Usage Comments: File detailed technical critiques of water demand projections, supply adequacy, drought impacts, and discharge temperature effects
- Require Pollution Transparency: Demand real-time public dashboards for emissions and water use, quarterly PFAS/chemical reporting, independent audits, and enforceable community oversight
- Challenge Strategic Siting: Oppose developments within 2 miles of residential areas, in environmental justice communities, or near sensitive ecosystems. Demand cumulative impact assessments
- Cite AI-Specific Water Research: Use University of Illinois research showing ChatGPT training consumed 700,000L of water and each 10-50 queries uses 500ml. Demand AI-specific water impact analysis in permits.
- Challenge PFAS and Chemical Risks: Demand comprehensive analysis of PFAS in cooling systems, leak detection plans, and groundwater monitoring requirements
- Demand Full Environmental Impact Statements: Trigger requirements for comprehensive EIS rather than limited environmental assessments
- Organize Scientific Expert Testimony: Present hydrologists, environmental scientists, and public health experts at public hearings
- File Administrative Appeals: Challenge inadequate permit conditions and environmental analysis deficiencies through formal appeals
Gateway Intervention
Campaign Playbook
Each campaign will have it’s own unique challenges and context. We are here to help talk through steps. The steps in this guide are informed by community victories so we aren’t reinventing the wheel. Contact us to talk about your campaign.
1. Scoping & Analysis:
Request all water usage and discharge applications. Engage hydrologists to review water supply adequacy. Identify all applicable environmental review requirements. File scoping comments demanding comprehensive EIS.
2. Technical Review & Comment:
Commission independent water impact studies. File detailed technical comments on draft permits. Present expert testimony on water supply and quality. Challenge inadequate PFAS and chemical analysis.
3. Enforcement & Appeals:
Monitor permit compliance and violations. File administrative appeals on inadequate permits. Organize community water quality monitoring. Coordinate with environmental justice advocates.
Valuable Allies
You don’t need to take on bad data centers alone. There are organizations and experts who can help. Explore the directory to find other leaders, and discover organizations in the Alliance Map.
Environmental Attorneys: Navigate permitting processes and file appeals
Hydrologists & Water Experts: Provide technical analysis of water impacts and testimony.
Environmental Scientists: Conduct comprehensive impact assessments
Public Health Advocates: Document community health risks
Environmental Justice Groups & Networks: Build partnerships to get support for specific actions
Gateway 3: Water Rights and Impacts
Resources & Documents
Essential tools and resource for this gateway.
