Water and Sewer Utilities

Stop excessive water use and prevent habitat loss

Data centers generate massive amounts of heat. As a result they need millions of gallons of water annually for cooling. Depending on the type of cooling system, some of this water may be recirculated, some evaporates, and some is eventually discharged offsite. If your data center is not using very much water, ask what it is using for cooling instead; it might be relying on more power for fans (i.e. more electricity) or chemical coolants.

As a result, these facilities often need permits to withdraw water for use, discharge it into waterbodies or wastewater treatment systems, manage stormwater from roads, buildings, and other impervious surfaces, and for any impacts to wetlands. The federal and state environmental laws that apply to these permits often require review processes that developers can’t skip. Most water issues are addressed at regional, state, or local levels.

In the arid western US, data centers need to purchase water rights in order to draw surface or groundwater. As long-term drought takes hold in the west, the oldest water rights have, in theory, top priority, making them an attractive target for data center water purchases. This could include tribes, farmers, or municipal users. You can keep an eye on this by finding out who has senior water rights in your watershed and keeping tabs on who is buying and selling or “renting.”

Data centers generally prefer to draw water from a water treatment facility and negotiating the amount can be a powerful leverage point for communities. Even if water is available, new or expanded infrastructure may be needed to get it to the facility. Water discharged from data centers generally requires a state permit that is based on federal discharge standards, which are not designed for pollution coming from data center sites. In addition, water discharged during construction, which might include runoff from the site and system “flushing,” is not always covered by operating permits and could be a significant short-term source of chemicals and suspended solids.

Water discharged from data centers can have high concentrations of pollutants like biocides (which are very commonly used to prevent algae from growing in the cooling system), corrosion inhibitors, and dissolved solids (which build up from repeated evaporation). The water can also be warm or hot (thermal pollution), elevating stream water temperatures beyond their threshold for their native species. Traditional water treatment plants are not designed to treat large volumes of water with these types of contaminants, so the pollution easily moves through the treatment plant and is discharged into the environment where it can pose risks for wildlife and downstream water users. Managing additions of warm water and biocides can also add costs and time to the water treatment process, because it often relies on biological communities of “bugs” that work best within a specific temperature range and that may be vulnerable themselves to biocides.

Construction of roads and buildings and surface runoff from parking lots can impair or destroy wetlands, triggering the need for permits to mitigate the impacts. Sometimes this habitat loss impacts threatened or endangered species, requiring additional reviews and permits.

Environmental reviews for water use, water discharge, wetland impacts, and endangered species habitats create public participation opportunities. Agencies must respond to substantive comments, and weak environmental analysis can be challenged through appeals and lawsuits. Threats to locally important resources can generate strong opposition.

This gateway matters because developers want quick approvals with minimal conditions and limited public disclosure. Since each site has unique power availability, timeline, and site-specific conditions, developers may not know the actual water needs and likely pollution levels until fairly late in the design process. Communities can raise concerns about the amount of water used, understanding how much and what happens to it, how it’s chemically and thermally changed within the facility, the costs of treating and discharging it, the impacts of discharges, and habitat and species loss. Communities can also highlight how developers’ stories about water needs change and are therefore potentially unreliable. These messages can be shared in public meetings, through written comments on proposed permits, and by getting the message out through traditional and social media channels. Partners may include scientists, hydrologists, engineers, farmers, recreational water users, environmental justice and community groups, hunting and fishing organizations, birdwatchers, and habitat conservationists.

When state environmental agencies and water and sewer authorities see organized community opposition backed by scientific evidence, they’re normally forced to take a harder look.

There’s a network of leaders sharing information, tools, events, and meeting to review specific topics on data centers.

Key Targets (Gatekeepers)

  • The agencies issuing water supply and water discharge permits. This varies widely by state and municipality.
  • Water resource managers (titles differ by location): State and local water authorities managing quantity and quality, sewer districts, and water boards can support or oppose water supply and discharge permits
  • Soil and Water Conservation Districts help local communities address conservation concerns arising from development and pollution
  • Regional Planning Organizations make recommendations and have some decisionmaking authority in some places about issues that cross municipal and state boundaries
  • State or federal environmental impact statement reviewers: these are the agency staff conducting national or state environmental quality reviews
  • Tribal Governments: especially crucial in areas where they have recognized historical rights to water or water-related rights of nature (e.g. fishing, sacred sites)
  • Environmental regulatory agencies: EPA regional offices and state EPA officials review and approve wetlands 401 permits

Possible Interventions

  • Monitor water quality both before construction to identify baseline levels of things like suspended and dissolved sediments, dissolved oxygen, pH, and stream depth, and then monitor again during construction to record violations such as excessive run-off or impacts to local water quality
  • Mandate advanced water management: Demand proof of water efficiency measures that reduce consumption by 80%+ compared to traditional cooling
  • Submit technical water usage comments: File detailed technical critiques of water demand projections, supply adequacy, drought impacts, impacts to nearby wells, and discharge temperature effects
  • Require pollution transparency: Demand real-time public dashboards for water use and discharge (including heat and chemical contamination), quarterly PFAS/chemical reporting, independent audits, and enforceable community oversight
  • Challenge strategic siting: Assess flood risks from data center discharges. Oppose developments within 2 miles of residential areas, in environmental justice communities, or near sensitive ecosystems. Demand cumulative impact assessments
  • Cite research (AI-specific when possible) on the impacts to water resources, water users, habitat, and endangered species
  • 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, water chemist, public health experts at public hearings
  • Recruit allies from the widest range of water and habitat users
  • File administrative appeals: Challenge inadequate permit conditions and environmental analysis deficiencies through formal appeals

Campaign Playbook

Each campaign will have its 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:

Find out who issues water supply and water discharge permits. Request all water usage and discharge applications. Engage hydrologists to review water supply adequacy. Identify what the impacts of water discharge might be. Identify all applicable environmental review requirements. File scoping comments demanding comprehensive environmental impact statements.

2. Technical Review & Comment:

Commission independent water impact studies. File detailed technical comments on draft permits. Present expert testimony on water supply and quality to support water moratoriums. Testify on the impacts of untreated water discharges to habitats, including any impacts on endangered species. Highlight the costs to the community of treating the data center water discharge in the municipal system. Challenge inadequate PFAS and chemical analysis.

3. Enforcement & Appeals:

Monitor permit compliance and violations. Track well contamination and water loss. File administrative appeals on inadequate permits. Organize community water quality monitoring. Coordinate with environmental justice advocates, outdoor recreation groups, and farmers.


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

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

Wetlands and local watershed protection organizations: Local groups advocating for water

Gateway 3: Water and Sewer Utilities

Resources & Documents

Essential tools and resource for this gateway.

Add A Resource

Environmental sustainability of data centres: A need for a multi-impact and life cycle approach (opens in a new tab)

Current data centre sustainability efforts focus narrowly on operational energy use, overlooking environmental damage from raw material extraction, equipment manufacturing and e-waste. Life Cycle Asse…

Documents Research
Source
Copenhagen Centre on Energy Efficiency (UNEP Copenhagen Climate Centre)
Published
February 1, 2020
Read more — Environmental sustainability of data centres: A need for a multi-impact and life cycle approach

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