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Hubbell Environmental Law Initiative and Tippie College of Business Social Impact Community
Considering Data Center Development in Iowa
A Practical Discussion for County Supervisors
August 20th, 2026. Iowa State Association of Counties Conference
Siting and Zoning
- Are appropriate zoning ordinances in place that address data centers (e.g., definition/category, noise, lighting, size, energy generation, waste heat, waste and materials)?
- Do current ordinances treat multiple buildings/phases under common control as one campus? Are thresholds based on building size, megawatts, water demand, backup generation, or other measurable impacts?
- Are special permits for data centers appropriate or already in place?
Siting and Zoning
- Have objective, use-specific standards (i.e. caps on sound at the property line) been considered?
- Are measurable performance standards embedded in code such as noise limits, lighting standards, setbacks from sensitive receptors, emergency access, hazardous materials, stormwater, construction hours, and periodic post-construction testing/reporting?
Siting and Zoning
- Does the code or ordinance require review of off-site power infrastructure or supporting utility (gas pipeline and/or high voltage transmission) upgrades that will affect environmental impact, and long-term capacity?
- Have impacts to adjacent properties and households been considered?
CASE STUDY
Linn County, Iowa – Key Energy and Data Center Sites
Data Centers Are Their Own Land Use
Do not force a hyperscale campus into office, warehouse, or generic industrial categories.
Traditional zoning buckets miss the operational profile
POWER USE COOLING
POWER GENERATION
CAMPUS SCALE
continuous large load MW scale + phasing
mechanical yards water / air / closed-loop
backup or temporary generators / BESS / islanded generation
multi-building buildout over several years
Planning lesson:
Define data centers separately, then decide scale tiers, approval path, and required information before the first application arrives.
LI NNN COUNTY
Regulate the Campus, Not Just the Building
A per-building threshold can miss the cumulative impact of phased hyperscale development. Two examples of ways to measure scale
VS. Linn County, Iowa Measures cumulative campus impacts. All related buildings and phases are counted together. > 20 MW electrical design capacity OR > 50 gpm annualized water use
Takeaway
A campus-level rule prevents a multi-building project from being reviewed as a series of smaller, disconnected approvals.
LI NNN COUNTY
Decide on Approval Pathway
Conditional/Special Use Permit
Dedicated Zoning or Overlay District
By Right
- Fastest approvals and greatest certainty for applicants
- Allows case-by-case review of local impacts
- Tailors standards to data center-specific impacts
- Least flexibility to address site-specific impacts
- More flexibility, but less predictability for applicants
- Most proactive and comprehensive planning approach
- Works best in carefully chosen areas
- Decisions can become political and inconsistent
- Takes more time and effort upfront
Loudoun County Example: how the approach evolved
Before 2014 → OFFICE USE SEPARATE USE 2014
2025 SPEX REVIEW
How you define the use determines where it belongs and whether it should be reviewed by right or case by case.
Turn Concerns Into Measurable Standards
The zoning role is to convert public concerns into reviewable requirements.
| Concern | Zoning Tool | |
|---|---|---|
| NOISE | → | dBA + dBC limits; receiving-property standard; pre/post testing; generator testing limits |
| VISUALS | → | setbacks from sensitive receptors; landscaped buffers; façade/equipment screening standards |
| CONSTRUCTION | → | traffic management plan; haul routes; hours; road-use agreement; temporary laydown permits |
| SCALE + PHASING | → | campus master plan; full buildout assumptions; phase triggers; related buildings counted together |
| INFRASTRUCTURE | → | utility coordination letters; power/water disclosure; emergency access; off-site impacts identified early |
Good standards are objective enough to administer and specific enough to address the actual impact.
LI NNN COUNTY
Water Transparency and Utility Coordination
Zoning cannot regulate the water system, but it can make the applicant, utility, and regulators answer the public's questions before approval.
PUBLIC QUESTION
APPLICANT DISCLOSURE
UTILITY + REGULATOR CHECK
ZONING DECISION
How much? Where from? What happens in a drought?
Require use estimate, source identification, cooling method
Capacity confirmation, Permit path, Contingency plan
Conditions, Phasing, Monitoring / reporting
Zoning usually cannot allocate water rights, set rates, or manage regional supply. It can require transparent, reviewable information.
Case Study: Water Transparency
Prince William County, Virginia — the emerging “water usage study” model
WATER USAGE STUDY
submitted before rezoning or site- plan approval
Demand average + peak usage
Cooling design water-based, air, closed-loop
Source potable / non-potable / reuse Management recirculation, efficiency, drought response
Utility review review + acceptance by water utility
Planning lesson: Make water demand visible, technical, and reviewable before approval.
Construction Impacts Don't Stop at the Zoning Boundary
A project approved in one jurisdiction can create road, traffic and temporary-use impacts in another.
LAND-USE APPROVAL City approves campus
CONSTRUCTION ROUTE Trucks, dewatering, staging
COUNTY IMPACT Roads + permits + coordination
Baseline road conditions
Regulatory response before construction begins
Approved haul routes
Repair obligations
One coordination contact
Key lesson: construction-management standards should follow the route, not just the zoning boundary.
Lessons Learned: Four Decisions Before the First Application
Final message: build the rules before the project.
___
Siting and Zoning: Table Discussion
Has your county received interest from data center developers, or do you anticipate it?
Are your zoning regulations and comprehensive plan prepared for potential data center developments?
What data center siting or land-use questions concern your county the most?
Community Considerations
- When and how do you plan to engage with residents to assess their perspectives about data center development in the jurisdiction?
- How will community perspectives be assessed and weighed (e.g., what if surveys and public comment indicate most residents do not favor development)?
- Could any public infrastructure or utility upgrades, special rates, discounted service, TIF, tax abatement, or other incentives offered to the developer/applicant shift costs or risk to existing residents, businesses, or taxing entities?
Community Considerations
If already engaging with a developer:
- Has the community established a proposed public-facing project timeline showing key meetings, required approvals, and when residents will have meaningful opportunities to review information before any final vote?
- In agreements, is confidentiality narrowly tailored, time-limited, ensures responses to requests in a timely fashion, and structured so that the public receives meaningful information before elected officials make final land use, utility, or incentive decisions?
- Has the developer shared projections about impacts to residential water and energy rates?
CASE STUDY
Community Considerations: four decision-process tools
The goal is to make benefits, risks, confidential claims, and participation points visible before the vote.
Build the process before the pressure
Moratoriums Create time to plan
Property taxes
NDAs Keep law in control
Transparency
Understand the value
Show the record
A temporary planning window can preserve the status quo while the community studies, engages, regulates, and reopens the process.
New construction can create major fiscal capacity, especially when existing revenue growth is capped. Confidentiality can protect true trade secrets, but Chapter 22 determines what may legally remain confidential.
Put documents, timelines, meeting dates, comment options, and updates where residents can find them.
These topics are connected: the public benefit only holds up when the public process is visible, lawful, and understandable.
LI NN COUNTY
Community Consideration: Moratoriums
Community trust depends on whether the public process can answer the questions that arrive with the project.
Sometimes the issue is not whether the project is good or bad. The issue is whether the existing planning framework is capable of answering the questions in public, on a record, before a vote.
What Is a Moratorium For?
Iowa case law supports the idea of a temporary pause as a planning bridge, not the final policy or permanent ban.
PRESERVE
Hold the status quo while the community determines whether existing rules are adequate. Gather facts, involve affected stakeholders, coordinate agencies and identify regulatory gaps.
STUDY
Geisler: preserve the status quo
The Iowa Supreme Court recognized interim development controls as useful for preserving the status quo while a local government performs its planning function and develops permanent regulations.
REGULATE
Translate the planning work into permanent standards, procedures and decision criteria.
Worthwhile Wind: build the framework
A county may respond to a proposed large-scale land use by adopting a temporary moratorium and new rules when no adequate regulatory framework exists; awareness of the project alone is not bad faith.
A moratorium is the bridge between realizing the rules are not ready and adopting the rules the community actually needs.
LI NNN COUNTY
Anatomy of a Well-Structured Moratorium
A practical design framework for supervisors and staff.
1
Defined purpose
What regulatory gap or public-welfare concern requires study?
2
Defined scope
What category of development is paused—and what is not?
3
Defined time
What is the sunset or end date?
4
Work plan
What studies, engagement, coordination and drafting will happen? How is the pause tied to health, safety, welfare and planning needs?
5
Public record
6
Clear exit
What permanent framework or decision will reopen the process?
Caution line from the cases:
Do not use a pause to illegally delay or defeat a properly submitted, conforming application. The defensible purpose is to create an adequate planning and regulatory framework.
The Goal Is a Better Decision
The measure of a moratorium is the framework that exists when the pause ends.
The goal is not to delay the decision. The goal is to improve the decision.
LI NNN COUNTY
Community Consideration: Property Taxes
Primary local-government benefit: new taxable value — and under Iowa's revenue caps, new construction is fiscal capacity.
One 280,000 SF building
Estimated taxable value: 280,000 SF × $400/SF = $112M
$2.49M-$3.24M
$15M-$19M
per year
gross property taxes / year before TIF, abatement, exemption, or incentive terms
Unincorporated $2.49M/yr
If six buildings are built
LI NN COUNTY
2
That scale explains why tax-base questions belong in the community-benefit discussion.
3 No growth means pressure
Existing base is capped
Most general levy growth is roughly limited to 2%.
New growth is the engine
New valuation/construction remains outside the cap.
No growth means pressure
If costs rise faster than 2%, service capacity shrinks over time.
Where one incorporated building tax dollar goes
$3.24M/year gross tax estimate for one 280,000 SF building
1
from one campus, before incentive-specific terms
Incorporated $3.24M/yr
Why new construction matters now
Community Consideration: Non-Disclosure Agreements (NDAs)
Confidentiality may protect true trade secrets — but lowa open-records law determines what can legally remain confidential.
A practical confidentiality protocol
A developer's preference for confidentiality is not the same thing as a legal exemption from disclosure.
1
2 Require written justification
Chapter 22 controls
4 Keep public summaries public
The NDA can set notice/process, but confidentiality exists only if Iowa law allows it.
Communities can ask why confidentiality is needed and limit it to specific information. Applicant identifies the exact information and provides the lowa Code §22.7 basis at submittal.
3
The community should know the assumptions behind the public decision: timeline, scale, water, power, roads, taxes, and enforceable obligations.
Do not assume an NDA is required
Non-confidential versions should explain the key facts needed for zoning and community decisions.
Linn County ordinance model
2 Applicant provides a written legal basis under Iowa Code §22.7.
1 Applicant marks specific information claimed as confidential at submittal.
County treats records under Chapter 22 – and may only keep records confidential when Chapter 22 allows it.
3
Takeaway: NDAs can organize confidentiality; they cannot replace public-records law or hide the basis for a public decision.
LI NN COUNTY
Community Consideration: Transparency and Public Communication
Residents should not have to hunt for application materials, meeting dates, comment options, or the decision timeline.
A strong project webpage answers four public questions
1
What is proposed?
2
Application packet, maps, technical studies, staff reports.
Where is it in review?
Process steps, meeting dates, status, voting points.
Linn County examples
One public-facing page can organize both the record and the public process.
EXAMPLE 1
Coggon Solar project page
- Application documents + staff report
- Review status table + meeting dates/videos
- Construction checklist
Open project webpage
3
How can I participate?
Comment form, public meetings, notification sign-up.
4
What changed?
Updates, new documents, third-party reviews, revised plans.
EXAMPLE 2
Morgan Valley Energy Center
- Application documents by topic
- Review process + future meeting notices
- Public comment link
Same facts · visible timeline · clear participation points
Open project webpage
Community principle: don't make people hunt for the record or guess when they can participate.
LI NN COUNTY
Community Considerations: Table Discussion
What would your community hope to gain from data center development planning and policies?
What concerns do residents raise around data center development?
How should local governments balance data center development opportunities with community priorities?
Potable Water & Wastewater
- What is the source of water for the data center?
- What amount of water will the data center need each day and each year (average day, maximum day, annual total, peak hours, and consumptive use versus water returned as wastewater or discharge)?
- What is the cooling strategy?
Potable Water & Wastewater
- What will the water be used for (drinking, industrial, non-potable)?
- How will water usage be reported?
- Would infrastructure be able to handle extra wastewater flow and the potential surge in flow to the system?
- Have water recycling processes been considered?
Potable Water & Wastewater
- What is the estimated start date of operation?
- Have seasonal or drought conditions been considered to eliminate shortages for residents as well as the data center?
- Would a higher water capacity be required for fire protection, which would require larger water infrastructure to the site (considering potential water utility impacts should they need to implement fire flow rates)?
Potable Water & Wastewater
If already engaging with a developer:
- Has a third-party regional water study or projection been undertaken that evaluates drought/low-flow conditions, competing users, utility capacity, and whether the proposed demand would affect service reliability for existing customers (ideally paid for by the developer/applicant)?
- Does a utility service agreement include conservation, curtailment, monitoring, reporting, and emergency/drought response provision?
Potable Water & Wastewater
If already engaging with a developer:
- Is the Iowa Department of Natural Resources involved in permitting, given the large volumes of water/wastewater?
- What is the water/wastewater ramp-up schedule (usually beginning with lower demand during construction and ramping up each time a building is brought online)?
CASE STUDY
We all live upstream from someone else... One Water – Healthy Waterways
- Safeguarding the Drinking Water Supply • Reducing the Risk of Flooding
- Reducing the Risk of Flooding
- Improving overall water quality
No Two Industries Are The Same...
- Closed Loop vs Evaporative Cooling vs Hybrid Cooling Systems
- Public System vs Wells/On-site Wastewater Treatment
- Fire Protection (Water Quality in the Pipeline?)
- Periodic Flushing Requirements
- Everyone is Highly Regulated
- Most Utilities Using a “Pay to Play” Business Model
- Water Recycling
- You Have to Grow A City To Grow A City
Potable Water & Wastewater: Table Discussion
Do you understand local current and future water capacity?
What additional information is needed about water capacity planning as it relates to data centers?
What water questions would you want answered before developing policies on data centers?
Energy
- What are the sources of power available to the data center?
- What amount of energy might the data center require, including megawatts at peak load?
- How will energy usage be reported?
- Will the data center use backup generation, temporary generation, on-site generation, or battery energy storage?
Energy
- Has renewable energy procurement been considered?
- What ordinances are in place that will oversee air quality emissions and noise associated with power sources?
- Will the local distribution utility conduct a rate assessment/impact study?
Energy
If already engaging with a developer:
- How many megawatts are needed, as well as transmission, substation, generation, battery or backup infrastructure and is the developer expecting to pay for those upgrades (which could affect costs or risks to other customers)?
- What is the ramp-up schedule (e.g., phased by building/campus phase, whether transmission/substation upgrades are needed)?
Energy
If already engaging with a developer:
- How flexible or inflexible will the data center's power demand be?
- Can the data center waste heat be reused?
- Has a third-party energy study been considered (ideally paid for by the developer or applicant)?
CASE STUDY
Energy and Iowa Data Centers
The Clean Energy Districts of Iowa (CEDI) is a non-profit corporation and an association of clean energy districts in Iowa.
There are currently 14 legally incorporated energy districts located in Allamakee, Cerro Gordo, Clayton, Delaware, Des Moines, Dubuque, Howard, Jackson, Johnson, Linn, Muscatine, Polk, Tama, and Winneshiek County.
CEDI Resource Hub Sections
| INTRODUCTION |  |
|---|---|
| BENEFITS and COSTS |  |
| LINN COUNTY, IOWA | A Case Study in Progress |  |
| ROLE of the IOWA UTILITIES COMMISSION |  |
| RESOURCES for CONCERNED CITIZENS and LOCAL GOVERNMENTS |  |
| RESOURCES for IOWA LEGISLATORS | [F8] |
Varying Sizes of Data Centers in Iowa
| MW | Facility Type |
|---|---|
| 1 - 30 | Crypto-Currency Mining Operations |
| 5 - 50 | Small and Mid-Size Edge Data Processing and Storage |
| 100 - 1,000 | Large Hyperscalers Servicing Cloud Computing and AI Operations |
Hyperscale Facilities Have Huge Power Demands
| 3 GW IN CAPEX PLAN | ~11% Retail Electric Sales Growth CAGR 2025-2031Demand expected to ramp up 2027-2031 | NEW RESOURCES NEEDED TO MEET LOAD | |||||
|---|---|---|---|---|---|---|---|
| Customer | ESA signed | ICR filed | ICR approved | Construction started | Load Ramp | 2-4 GW | New signed ESA for 370 MW in lowa with full ramp by end of 2030, will be included in Q3 capex plan updateSecured generation to serve new load |
| QTS 1Cedar Rapids, IA | ✓ | ✓ | ✓ | ✓ | 2026 - 2029 | ||
| Google 1Cedar Rapids, IA | ✓ | ✓ | ✓ | ✓ | 2026 - 2028 | Mature opportunities with the start of load ramp expected in 2029 or later | |
| MetaBeaver Dam, WI | ✓ | ✓ | ✓ | ✓ | 2026 - 2027 | ||
| QTS 2Clinton, Iowa | ✓ | 2028 - 2031 | Beyond 4 GW | Opportunities at various stages of explorationBeyond current planning period | |||
| ~50% INCREASE IN PROJECTED DEMANDby 2031 (from 2025 base of ~5.5 GW max demand) | UNLOCKING THE POTENTIAL OF CUSTOMERSAND COMMUNITIES | ||||||
7
ESA = Electric Service Agreement ICR = Individual Customer Rate
Huge Demand Requires More Generation
Is your county interested in hosting data centers? If so, to what extent is your county willing to host new electricity generation facilities to power data centers in your county or other lowa counties?
- Wind, solar, and/or energy storage
- Coal or natural gas
- Nuclear power
Siting Restrictions Can Raise Complex Issues
On the one hand, counties can impose varying restrictions via ordinances to discourage certain types of generation facilities.
On the other hand, the Iowa Utilities Commission (IUC) is charged by law with the task of issuing a Certificate of Public Convenience, Use and Necessity for new generation facilities.
- Does your county have the resources to intervene in these IUC dockets to support or oppose these new facilities?
- Does your county have the resources to challenge IUC decisions in court?
Protecting Constituents is Important
Fuel Costs
- What is the best way to protect ratepayers in your county from higher utility bills due to increased demand for natural gas?
Generation and Transmission Facility Cost Recovery
- What is the best way to ensure that these costs are assigned to the new large loads requiring them?
Air Quality
- What is the best way to protect citizens in your county from the air pollution arising from new generation facilities in your county or backup facilities at the data centers?
Energy: Table Discussion
Do you understand current and future local energy capacity?
What additional information is needed about energy capacity planning as it relates to data centers?
What energy questions would you want answered before developing policies on data centers?
Hubbell Environmental Law Initiative and Tippie College of Business Social Impact Community IOWA
IOWA
Open Discussion: Audience Questions
For more information about the Iowa Data Center Decision Tool, please contact Jennifer Terry, jennifer-terry@uiowa.edu
Mae MFDong[5]
Program Coordinator
Planning & Development Director
Tippie College of Business mae-mcdonough@uiowa.edu
Linn County
charlie.nichols@linncountyiowa.gov
[F621]
[F32]
[F36]
[F42]
[F232]
[F45]
[F27]
[F68]
[F33]
[FR3] [F77]
[F45]
[F87]
City of Cedar Rapids
Clean Energy Districts of Iowa
r.hesemann@cedar-rapids.org
james.martin-
schramm@cleanenergydistricts.org