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Item 1. Zoning Ordinance-Data Centers 3601 Thurston Avenue Anoka, MN 55303 763.231.5840 TPC@PlanningCo.com 1 MEMORANDUM TO: Otsego Planning Commission FROM: D. Daniel Licht DATE: 2 July 2026 RE: Otsego – Zoning Ordinance; Data Centers TPC FILE: 101.01 BACKGROUND Considerable attention is being given to the development of data centers in Minnesota and nationwide as the demand for these facilities has increased with the expansion of internet-based services resulting in both more facilities and larger facilities. Proposals for data center developments have generated controversy due to perceptions about potential impacts and compatibility concerns in other communities. Otsego has not received an application for development of a data center, and no known projects are pending. It is advantageous for the City to anticipate potential development of various land uses in establishing allowed uses and performance standards within the Zoning Ordinance. This approach allows a broader consideration of the characteristics of, and potential issues associated with, various land uses and how to allow and regulate them instead of having to react to an application for a specific project. The City Council Administrative Subcommittee raised the question as to how data centers are regulated by the City and directed the Planning Commission to study this matter in further detail. This memorandum outlines initial topics for consideration related to data centers as a land use and potential regulations. The Planning Commission will discuss data center regulatory concepts at a work session on 6 July 2026. Exhibits: • Future Land Use Plan map • Understanding Data Centers, National League of Cities • Data Centers; Zoning Practice Issue #6, APA, June 2022 • The Physical Footprint of Artificial Intelligence; Zoning Practice Vol. 42, APA, October 2025 2 ANALYSIS Definition. The Zoning Ordinance does not include a definition of data center as a distinct land use in Section 11-2-2. To establish regulations to address the specific characteristics of data centers, adopting definitions will be necessary. The regulation of data centers is intended to apply to facilities as a principal use of property, taking one of two forms. The first is a stand-alone facility within a single building that may be owned or operated for one business operation. The other, which is the source of most interest and controversy, is a data center campus (or data farm) having multiple principal buildings providing internet-based services as a core business function. City staff has drafted the following initial definitions for future inclusion in the Zoning Ordinance, which would not include accessory uses: • Data center: A facility within a single building used primarily for the storage, management, processing, and transmission of digital data, which houses computer or network equipment, systems, services, appliances, and other associated components related to digital data storage and operations, together with its accessory and appurtenant facilities, which may also include offices, air handlers, back-up power generators, water cooling systems and water storage facilities, utility substations, and other associated infrastructure necessary to support sustained operations at a data center. • Data center campus: A facility comprised of more than one data center building, that may be located upon one property or contiguous properties owned or operated by a single business operation ol that are otherwise interconnected by power supply, communication systems, power generation or other operational systems to form a unified data center facility. This definition includes uses described by terms such as “technology campus”, “cloud computing campus” or similar phrases and terms. Land Use. Data center operations are a form of commercial or industrial activity. Data centers provide services, but do not involve extensive office operations. Data centers do not involve physical industrial processes such as manufacturing, assembly, processing, or warehousing and do not generate significant traffic either from passenger vehicles or semi-tractor/trailers. The site and building plans are industrial with precast concrete buildings or similar industrial building types. Data centers may also have equipment such as cooling systems, electric transformers, or generators outside of principal buildings. The Future Land Use Plan map guides areas within the City for development of commercial, office, and industrial activities. Based on the characteristics of data centers, they would be appropriately located on properties guided for Office or Industrial land uses. Office land uses have been guided for properties adjacent to Commercial land uses with the intent of developing smaller-scale, high-employment operations that would serve to provide daytime market support for commercial retail and service businesses to increase market vitality. Data centers are likely most appropriately addressed as industrial uses to be allowed only in areas guided for Industrial land use by the Future Land Use Plan. 3 Zoning Districts. The City has statutory authority as a legislative action to determine the zoning districts in which specific uses are to be allowed. The Zoning Ordinance currently allows data centers as a permitted use within the B-4, Business Office District; I-1, Limited Industrial District; and I-2, General Industrial District. Based on the land use discussion above, data centers should not continue to be an allowed use within the B-4 District. Inclusion of data centers in the I-1 District and the I-2 District is appropriate from a land use perspective, but allowance as a permitted use may be problematic. Permitted uses are allowed within various zoning districts subject to compliance with the performance standards of the Zoning Ordinance. Section 11-9-2 of the Zoning Ordinance provides that proposals for specific developments within the I-1 District and the I-2 District require applications for site and building plan review that are subject to review by the Planning Commission and approval of the City Council. No public hearing is required by State Statute or the Zoning Ordinance for site and building plan review applications. Site and building plan review decisions are to be based strictly on established performance standards; there is no opportunity for discretion related to potential impacts of a specific development such as for compatibility with the surrounding area, impacts on traffic, or impacts to City services and infrastructure. Uses allowed as conditional uses within a zoning district are subject to a more robust review process that affords the City authority, albeit still limited, to consider proposal specific factors and includes opportunity for public input through a required public hearing. Due to perceived concerns for potential negative impacts of data centers including, but not limited to, water use, electric service demands, noise, exterior lighting, City staff recommends that continued allowance of data centers within the City be as a conditional use. However, itt must be emphasized that the conditional use review process provides discretion only within adopted standards and legally supported conditions; community opposition to a proposed development alone is not legal justification for a conditional use permit application to be denied. Defining data centers as a single principal building and data center campuses as multiple principal buildings or properties under common ownership and operation also allows the City to determine where data center uses are appropriate based on their intensity. The City may elect to allow data centers in both the I-1 District and the I-2 District, while allowing data center campuses only in the I-2 District. The size of the facility in terms of building square footage or service capacity may also be used to determine appropriate location for data centers by zoning district. Determining whether to allow data centers and data center campuses as a conditional use in one or both the I-1 District and I-2 District should consider the locations guided by the Future Land Use Plan for light industrial and industrial land uses corresponding to these zoning districts, respectively. Lot Requirements. The Zoning Ordinance establishes minimum lot area and width requirements for each zoning district for the purpose of subdividing larger tracts into smaller lots that can be feasibly developed with the uses allowed within the zoning district. The minimum lot area and width requirements are supplemented by building coverage and impervious surface limits to control the bulk of development within a lot, provide greenspace for screening and aesthetics, and facilitate stormwater management. As these standards are minimums, the larger or more intense the use of a property, these standards (together with minimum setback requirements) may result a larger lot area to offset the increased intensity of the use. A requirement for data centers to have a larger minimum lot area, lot width, or specific building coverage and impervious surface limits may be considered as a means of providing physical separation of a data center from surrounding uses. 4 Setback. Minimum setbacks from property lines are established generally for each zoning district. The primary purpose of setbacks is physical separation from public streets for visibility or from surrounding land uses for compatibility and aesthetic reasons. Setback requirements also work to facilitate functional site plans in terms of access and circulation within a lot and avoidance of congestion on public streets. A setback requirement may also be established for specific uses to provide for increased separation from surrounding uses that may be potentially sensitive to compatibility issues. The concerns about data centers for land use compatibility typically pertain to surrounding residential uses. To this end, the City may consider a setback requirement for data centers from properties guided by the Future Land Use Plan for future residential use, residential zoning districts, existing residential uses or a combination thereof. Requiring an increased setback serves to mitigate potential impacts of a data center. An increased setback requirement for data centers from properties guided for residential land use, residential zoning districts, or with existing residential uses may also be made reciprocal. A reciprocal setback requirement would not allow a new residential use to be established within the setback area of an existing data center. This preserves the desired separation between data centers and residential uses long term ensuring that no new compatibility issues are created by residential uses encroaching close to an existing data center. The Future Land Use Plan includes areas guided for Industrial land use at the perimeter of the City abutting the City of St. Michael, City of Albertville, and Monticello Township. Establishing a setback requirement from properties guided, zoned, or used for residential purposes cannot be applied across city boundaries as the City does not control the land use within the abutting jurisdiction. If there is a concern of the Planning Commission as to potential impacts of a data center crossing over a City boundary, a setback from a jurisdictional boundary may be considered for the same purpose of mitigating potential noise, exterior lighting, and visual impacts. Water Use. Data centers employ cooling systems to dissipate heat and maintain the facilities and equipment at required temperatures. Use of water-based systems has potential for issues related to surface waters, groundwater resources, utility system capacity, and water rates. Cooling may be accomplished using either water- or air-based systems, although new alternatives are being developed with the intent of reducing demand for water use. Mandating use of closed-loop water systems, for example, can mitigate concerns regarding excessive water usage for data centers. The development of a data center in Otsego would be subject to mandatory connection to City water utilities as required by Section 8-1-3 of the City Code. The City water system operates under a permit approved by the Minnesota Department of Natural Resources for appropriation of water. The aquifers from which the City draws water are deep underground; water use from these aquifers does not significantly affect water supplies for individual private wells. The City has adopted a Water System Master Plan that guides the operation and expansion of the water utility system. The Water System Master Plan estimates future water use based on growth forecasts and existing and future land uses guided by the 2023 Otsego Comprehensive Plan. Water system improvements are not funded by general City funds, such as property taxes, but by utility access and connection fees paid by new development and user fees. Timing for improvements to the water system to add capacity or expand the service area planned by the Water System Master Plan is coordinated with the Capital Improvement Plan to estimate costs and allocate funding to ensure financial sustainability for the City generally and system users who pay utility bills. 5 One of the criteria in Section 11-4-2.F of the Zoning Ordinance for considering an application for a Conditional Use Permit is that “the proposed use can be accommodated by existing public services and facilities and will not overburden the City's service capacity”. The City may establish a requirement that a application for approval of a data center as a conditional use include water consumption plan to outline water use requirements for the proposed use and impacts to municipal water supplies and groundwater or surface water resources. This study would be evaluated by the City Engineer to determine whether the City water system has capacity to accommodate the proposed use as well as other planned development consistent with the 2023 Comprehensive Plan and Water System Master Plan. If the City determines that there is not sufficient capacity available or planned to accommodate the proposed data center, the City, at its discretion, may require the developer to fund the necessary improvements or deny the Conditional Use Permit application. Electric Service. There are three high-capacity electric transmission lines that bisect Otsego and substations that could be used to serve data center uses. Proposals for the development of data centers in other jurisdictions has brought forward concerns about costs for electric infrastructure and utility rates. Electric utilities are defined as essential services and regulation of electric utilities is largely beyond the City’s jurisdiction, addressed at a State level by the Public Utilities Commission. The City is only allowed to regulate electric overhead transmission lines and substations up to 100 kilovolts. Services less than 33 kilovolts are subject to administrative approval whereas facilities of more than 33 kilovolts and up to 100 kilovolts require approval of a conditional use permit in all zoning districts. An application for development of a data center may require electric utility improvements that are subject to City regulation in accordance with Chapter 32 of the Zoning Ordinance. The City may, as part of a conditional use permit review process, require an electric consumption plan to be submitted to identify electric service needs as represented by the utility provider and any improvements associated with the proposed use. The need for additional transmission lines to provide service to a proposed data center would also be required to be identified so that the new infrastructure can be evaluated concurrent with the data center proposal. Noise. Cooling systems utilized by data centers generate noise, which has been identified as a primary concern for perceived impacts from data centers. The concern expressed relates not only to the sound level, but also to the constant nature of the noise. • The City has adopted Minnesota Pollution Control Agency noise regulation rules as Section 11- 16-10 of the Zoning Ordinance as a general performance standard, which would apply to data centers. The City may also consider data center specific standards such as the range of sound regulated. • Noise mitigation can also relate to addressing water use concerns; cooling fans are the main source of sound from data centers. Requiring closed-loop or alternatives to fans can mitigate noise generation for data centers as well as minimize water use. • Setback requirements are also an effective means of noise mitigation as sound levels decrease exponentially over horizontal distances. 6 The City may require, as part of the conditional use permit process, a noise study to be submitted that details existing noise levels, outlines noise mitigation to be employed by the facility, and estimates post- development noise levels. Cities have also used a requirement for a post-development sound study to demonstrate the accuracy of the initial study estimates and effectiveness of the noise mitigation once the facility is operational. The pre- and post-development noise studies are important for the City to be able to determine compliance with established performance standards for noise generation either generally or specific to data centers. Screening. Data centers may have equipment or facilities that are not fully enclosed within a building. The Zoning Ordinance includes general performance standards for required screening in Section 11-19- 3. The performance standards for data centers as a conditional use may include requirements that any equipment or facility not enclosed within a building must be screened using berms, landscaping, fences/walls, or a combination thereof with minimum height and opacity requirements. Setback requirements may also be used as a means of screening a data centers from view of major roadways and surrounding uses. The Planning Commission has had extended discussions as to screening for recent industrial development applications involving outdoor storage, such that consideration of screening requirements for data centers may also serve as a basis for an update of general screening performance standards for all commercial, office, and industrial uses within the City. Exterior Lighting. The Zoning Ordinance establishes limits for exterior lighting in Section 11-16-6 of the Zoning Ordinance. The City may consider developing exterior lighting performance standards for data centers as a conditional use such as limiting the amount of blue light allowed, decreasing the maximum intensity of allowed exterior lighting, or requiring that exterior lighting be reduced during overnight hours. City staff would note that the current lighting standards of the Zoning Ordinance were adopted in 2002 before the advent of LED exterior lighting. City staff has noted concerns that the current Zoning Ordinance standards do not adequately regulate LED lighting related to the list of potential issues above. To this end, the Planning Commission may consider developing lighting standards for data centers as a parallel effort to an update of the general performance standards of the Zoning Ordinance to be applied to all commercial, office, and industrial uses. Environmental Review. Minnesota Rules Chapter 4410 establishes requirements, procedures, and criteria for environmental review for development. The purpose of environmental review is to evaluate and understand the potential effects that a development will have on the environment. Environmental review documents contain information that addresses the significant environmental issues of a proposed development and is made available to governmental agencies and the public early in the development review process. The environmental review process is intended to guide issuing, amending, and denying development applications to avoid or minimize adverse environmental effects and to restore and enhance environmental quality. Environmental review informs government decision-making but does not itself approve or deny a proposed project. Environmental review involves preparation of studies based on information requirements set forth by Minnesota Rules. An Environmental Assessment Worksheet is a preliminary scoping document to determine if a development has potential for significant environmental effects. The findings of an Environmental Assessment Worksheet are used to determine if preparation of a more detailed and comprehensive Environmental Impact Statement is to be required. Environmental review may also follow a process known as Alternative Urban Area Review that addresses substantially the same issues and follows the same process as the Environmental Assessment Worksheet and Environmental Impact Statement. In most cases, the City serves as the Responsible Government Unit for reviewing the environmental review and making findings as to potential for significant environmental effects. 7 Minnesota Rules 4410.1000 and 4410.2000 establish provisions for when a project requires preparation of an Environmental Assessment Worksheet or an Environmental Impact Statement, respectively. There is no specific requirement in Minnesota Rules for requiring environmental review for data centers, which is a potential State-level regulatory topic. The most likely triggers for mandatory preparation of an Environmental Assessment Worksheet or an Environmental Impact Statement are the conversion of undeveloped land for industrial use based on acreage or construction of industrial building square footage exceeding specified thresholds. The City may require preparation of an environmental review as a discretionary action if it determines, at its discretion, that a proposed project may have the potential for significant environmental effects. Minnesota Rules 4100.1100 also provides for a petition process whereby any person may request the preparation of an Environmental Assessment Worksheet for a project by filing a petition signed by at least 100 individuals who reside in or own property in the State, although the Responsible Government Unit determines if the environmental review is to be required. Implementation. The discussion provided by this memorandum serves as a general outline for development of amendments to the Zoning Ordinance to address allowance and regulation of data centers within the City. Immediate focus needs to be given to defining data center uses, determining the zoning districts data centers and data center campuses are to be allowed in, and changing data centers and data center campuses from permitted uses to conditional uses within the zoning districts the uses are to be allowed in. A more concentrated effort will be needed to develop performance standards to address perceived compatibility issues and impacts to City services and infrastructure. Otsego is not the only government jurisdiction initiating a review of data center regulations. Cities and counties (including Wright County) throughout Minnesota and nationally are undertaking similar efforts either in anticipation of or in response to development proposals. There is also growing discussion as to the need for State-level regulation of data centers, especially in terms of electric utility use and environmental impacts. State level regulations would take longer to develop and implement as a legislative process than a city may implement through zoning regulations. Amendment of the Zoning Ordinance to ensure appropriate allowance and regulation needs to occur in a timely manner to have provisions adopted prior to a data center being proposed in Otsego. However, it would also be beneficial for the City, in developing its own regulations, to review and consider the efforts of other government jurisdictions. Minnesota Statutes Section 462.355, Subd. 4 allows the City to adopt an interim ordinance establishing a moratorium for the purpose of preparing development regulations. A moratorium may be established for a period of one year from the date of adoption. If amendments to the Zoning Ordinance are complete before the end of the moratorium period, the moratorium can be repealed. The Statute also provides that a moratorium can be extended if certain criteria are met. Minnesota Statutes Section 462.355, Subd. 4 requires that the City Council conduct a public hearing to consider the proposed interim ordinance. City staff requests that the Planning Commission make a recommendation to the City Council as to establishment of a moratorium for data center uses to allow for consideration of amendments to the Zoning Ordinance regulating such uses. 8 CONCLUSION The Planning Commission will have an initial discussion of data centers and data center regulations at a work session on 6 July 2026. The purpose of this work session is for questions and comments from the Planning Commission about data centers and how the City may consider regulating this land use. City staff requests the Planning Commission recommend whether the City Council should establish a moratorium to allow further study without concern for an application being submitted that the City would be required to react to. c. Adam Flaherty, City Administrator/Finance Director Audra Etzel, City Clerk Ron Wagner, City Engineer David Kendall, City Attorney 456738456738456742456742456742456742456736456739456739456739456719456719§¨¦94456737456718EF137456738FUTURE LAND USE PLAN00.510.25MilesÉK:\cad_eng\PROJECTS\GIS\TPC\Otsego\Comprensive Plan 2012\Future Land Use MapDISCLAIMER:This product is for informational purposes and may not have beenprepared for, or be suitable for legal, engineering, or surveyingpurposes. Users of this information should review or consult theprimary data and information sources to ascertain the usabilityof the information. LEGENDPlanning DistrictsRuralRural ResidentialLD Residential (Large Lot)LD ResidentialLMD ResidentialMHD ResidentialMixed UseCommercialOfficeIndustrialLight IndustrialPublic/Quasi PublicCOMPREHENSIVE PLAN 2023ADOPTED:AMENDED:Res 2023-52,14 Aug 23Res 2024-52, 22 Jul 24 AMERICAN PLANNING ASSOCIATION ZONING PRACTICE JUNE 2022 ISSUE NUMBER 6 PRACTICE DATA CENTERS 6 ZONINGPRACTICE 6.22 AMERICAN PLANNING ASSOCIATION | page 2 Zoning for Data Centers and Cryptocurrency Mining By David Morley, aicp Data centers are the physical facilities where the internet lives. Fundamentally, they con- sist of networked computer systems used for data storage and processing, along with supporting equipment, such as batteries, back-up power generators, and cooling devices. Modern data centers are the direct descendants of the, so-called, telecom hotels that began springing up in downtowns in the late 1990s to accommodate the rapid expan- sion of the commercial internet and, before that, of automated telephone exchange facilities that made it possible to place land- line telephone calls across a city, the nation, or the world (Evans-Cowley 2002). An emerging segment of the data center market consists of facilities dedicated in whole or part to “mining” cryptocurrency. A cryptocurrency is a decentralized digital currency that uses encrypted data strings to denote individual units, or coins, and a peer- to-peer database known as a blockchain to maintain a secure ledger of transactions. Several of the most popular cryptocurren- cies, most notably Bitcoin, require extremely complex computations to verify each trans- action and add a record, or block, for that transaction to the blockchain. Whoever verifies a transaction first receives a new cryptocurrency coin as a reward. While, theo - retically, anyone with a computer server can “mine” new coins by helping to verify these transactions, large-scale cryptocurrency mining requires a massive amount of com- puting power. This article explores the reasons why cities, towns, and counties may wish to define and regulate data centers and cryp- tocurrency mining as distinct uses in their zoning codes and provides a summary of contemporary approaches. It begins with a brief overview of the factors that drive demand for data centers or cryptocurrency mines in particular locations before examin- ing the key planning issues that may merit special attention through zoning and posing a series of questions to guide code drafting. The article concludes with short profiles of local zoning approaches that may serve as models for others. DEMAND DRIVERS Industry analysts predict sustained growth in data center construction in the coming years (Dunbar and Bonar 2021). This includes demand for larger and larger “hyperscale” data centers as well as more widely distrib- uted “edge” data centers (Sowry et al. 2018). Data center developers (or operators) are attracted to sites with low latency to end users and dependable and affordable elec- tricity. While data centers have historically been clustered around major internet access points, information technology companies, and government employment centers, the proliferation of cloud computing and the internet of things is pushing demand out to network edges. This means more data centers in smaller metropolitan and nonmet- ropolitan areas. Big technology companies are likely to continue looking for sites that can accommo- date new, large single-story structures. But operators that specialize in leasing space in the same facility to multiple companies (i.e., collocated data centers) may be more open to infill sites and existing structures, espe- cially if those sites have access to fiber optic infrastructure. Data centers use a lot of electricity (see below) to power processing and stor- age hardware and to keep that hardware cool. The amount of electricity (and often water) needed for cooling is higher in warm, humid climates than in cool, dry areas. Consequently, holding other factors equal, developers favor locations with low electric- ity rates and cooler climates. Furthermore, because these facilities operate continu- ously, developers are also looking for sites that are less vulnerable to natural hazards. Cryptocurrency miners are also look- ing for locations with cheap electricity and low hazard risk; however, dedicated mining facilities are not concerned about proxim- ity to customers and are less likely to invest in backup power. While there seems to be a widespread consensus that data centers are essential to global communications and the global economy, cryptocurrency miners Chad Davis / Flickr (CC BY 2.0)A hyperscale Google data center in Council Bluffs, Iowa. ZONINGPRACTICE 6.22 AMERICAN PLANNING ASSOCIATION | page 3 have a more limited “social license” to oper- ate. Widespread concerns about the energy use of mines and the limited utility of the coins they produce has led some countries, including China, to ban Bitcoin mining. Con- sequently, many cryptocurrency miners are relocating to the U.S. (Obando 2022). PLANNING ISSUES From the exterior, data centers and crypto- currency mining facilities may be physically indistinguishable from many commercial or light industrial uses. However, the operational characteristics of these facili- ties are typically quite distinct from those of surrounding land uses. From a planning perspective, the most noteworthy character- istics relate to their electricity and water use, noise production, enhanced safety and secu- rity needs, and low employment densities. They Use a Lot of Electricity (and Water) In 2020, data centers used between 200 and 250 terawatt hours (TWh) of electricity, accounting for approximately one percent of global consumption (IEA 2021). While the total consumption has grown steadily along with global power demand, this ratio has held relatively constant over the past 20 years as efficiency improvements have proportionally offset increased demand from data centers. However, this pattern is unlikely to hold as growth in streaming video, online gaming, cloud computing, machine learning, virtual reality, and the internet of things begins to outstrip effi- ciency improvements. The figures above exclude cryptocur- rency mining. Bitcoin miners alone used an estimated additional 60 to 70 TWh in 2020. According to Cambridge University, if Bitcoin was country, it’s annual electricity consump- tion would be slightly higher than that of Poland or Malaysia (2022). Data center and cryptocurrency mining equipment also generates a tremendous amount of waste heat, which must be dis- sipated by fans or absorbed by a cooling medium to avoid hardware damage and ensure efficient operations. Many data cen- ters and cryptocurrency mines use water as a cooling medium. Water is also necessary for most forms of electricity production. In aggregate, a medium-sized data center typi- cally uses more water each year than two 18-hole golf courses (Mytton 2021). They Can Be Noisy Inside a data center or cryptocurrency mine server room, the noise can make it difficult to carry on a conversation at a normal volume. While most data centers and large crypto- currency mines incorporate construction and soundproofing techniques that ensure this server noise isn’t audible outside of the building, air conditioner compressors mounted on the roof or on ground near these facilities can generate noise that carries across property lines. In some contexts, vegetation or other structures may rapidly attenuate this sound. In others, the sound may travel over long distances. Obviously, the degree to which these sounds constitute nuisance “noise” depends on surrounding land uses and ambient noise levels. The problem is typically most acute when data centers or mines are near residences. They Have Enhanced Safety and Security Needs Data centers typically aim to run con- tinuously, and any outage or downtime can threaten business operations. Furthermore, data centers house expensive, highly specialized hardware, and many handle sensitive data. Consequently, most data centers incorporate enhanced safety and security features, such as gated access points, fencing, or bright lighting, to prevent unauthorized access and to minimize the likelihood of disruption. Cryptocurrency mines have similar safety and security needs, with two key distinctions. First, miners want to maintain network access, but the stakes are lower than for data centers because an outage wouldn’t negatively affect any other services or users. Second, cryptocurrency mines gen- erally aren’t receiving any clients and have little incentive to draw attention to them- selves with fencing or lighting. They Have a Low Employment Density Data centers typically have far fewer workers per square foot than professional offices or light industrial facilities (Tarczynska 2016). And cryptocurrency mines generally have even lower employment densities than data centers. For some communities, data centers (and potentially cryptocurrency mines) are highly desirable from an economic devel- opment perspective because they often generate a large property tax surplus that can subsidize more service-intensive land uses, such as single-family homes. Others, however, are reluctant to devote too much commercial or light industrial space to uses that generate few jobs. ZONING CONSIDERATIONS Any community interested in regulating data centers and cryptocurrency mining through zoning should consider three key questions: 1. Do these uses need new use definitions? 2. Where should these uses be permitted? 3. Do these uses need special development or performance standards? Do They Need New Use Definitions? New land uses don’t necessarily require new use definitions in the local zoning code. It depends, in part, on whether the use fits ebayink / Flickr (CC BY-NC-ND 2.0)The roof of eBay’s Topaz data center in South Jordan, Utah. ZONINGPRACTICE 6.22 AMERICAN PLANNING ASSOCIATION | page 4 neatly under a broader use category or is substantially like another defined use. And it depends on whether treating the new use the same as this use category or other simi- lar use would be likely to generate negative effects on nearby properties or the commu- nity as a whole. Many communities have defined data centers (or some closely analogous term) as a distinct use in their zoning codes. These definitions typically reference the general function of the facility and the degree to which it is occupied by computer systems and related equipment. For example, Anne Arundel County, Maryland, defines data stor- age center as “a facility used primarily for the storage, management, processing, and transmission of digital data, which houses computer or network equipment, systems, servers, appliances, and other associated components related to digital data storage and operations” (§18-1-101.(44)). Comparatively fewer communities have defined cryptocurrency mining as a distinct use. Many of these definitions focus on the specialized purpose of the facility, often with references to other newly defined terms, such as high density load or server farm, that clarify its distinct characteristics. For example, Moses Lake, Washington, specifies that cryptocurrency mining often uses more than 250 kilowatt-hours per square foot each year (§18.03.040). Where Should They Be Permitted? Communities that choose to regulate data centers or cryptocurrency mines as distinct uses may permit these uses either by right or with a discretionary use permit (i.e., conditional, special, or special exception use permits) in one or more existing base or overlay zoning districts. Alternatively, they may elect to establish a new special-purpose base or overlay zoning district for either use. Many communities permit data centers and cryptocurrency mines either by right or with a discretionary use permit in com- mercial and industrial districts. While data centers and mines can fit in a wide range of existing commercial or industrial buildings, purpose-built facilities are often single-story structures with large floorplates. Given that they generally have few employees and visitors, these uses may not be appropriate in ground-floor street- frontage spaces in pedestrian-oriented commercial areas. Wenatchee, Washington, addresses this issue by permitting data centers and cryptocurrency mines by right in multiple pedestrian-oriented commercial districts, with a simple stipulation that they cannot occupy “grade level commercial street frontage” (§10.10.020). A new special-purpose zoning district can help steer data centers or cryptocurrency mines toward corridors or other subareas that have suitable utility infrastructure. When adopted as floating zones, special districts can also provide an extra layer of review for large projects that may cover doz- ens or hundreds of acres. Prince William County, Virginia, added a Data Center Opportunity Zone Overlay Dis- trict to its zoning code in 2016 (§32-509). The county has mapped this overlay to more than 70 percent of its industrially zoned land. The overlay permits data centers and includes design standards for these facilities; however, it does not otherwise modify the existing use permissions for underlying districts. Do They Need Special Development or Performance Standards? Communities that decide to regulate data centers or cryptocurrency mines as distinct uses may choose to adopt use-specific standards that modify or supplement other relevant universal or district-specific devel- opment or performance standards. This approach can help communities target stan- dards to the distinct features of these uses to address specific community concerns. Use-specific standards can help mini- mize reliance on discretionary approvals and improve the consistency of local decisions. Without these standards, local officials may be more likely to require all data centers and cryptocurrency mines to obtain a discretion- ary use permit, and they may be more likely to adopt wildly varying conditions of approval for substantially similar proposals. Communities that have adopted use- specific standards for data centers and cryptocurrency mines often establish building design and buffering or screening require- ments to minimize the visibility or improve the appearance of these facilities from public streets or nearby properties. Other common standards address environmental perfor- mance, including noise and light pollution, and evidence of electric utility approval. POTENTIAL MODEL APPROACHES It would be difficult to find a community with more experience with data centers than Loudon County, Virginia. And the county’s approach to zoning for data centers serves as a potential model for other communities with suitable sites and sufficient infrastructure to accommodate data center development. In contrast, Missoula County, Montana, was one of the first local jurisdictions to craft zoning regulations for cryptocurrency mining opera- tions. And its emphasis on mitigating the potential climate impacts represents a differ- ent type of potential model. EXAMPLES OF DEFINED USES Jurisdiction Defined Uses Alpharetta, GA Data center (§1.4.2) Anne Arundel County, MD Data storage center (§18-1-101.(44)) Fairfax County, VA Data center (§9103) Frederick County, MD Critical digital infrastructure facility (§1-19-11.100) Moses Lake, WA Cryptocurrency mining; Data center/server farm/cluster (§18.03.040) Pitt County, NC Data processing facility (large scale) (§15) Plattsburgh, NY Commercial cryptocurrency mining; Server farm; High density load service (LL 6-2018) Prince George’s County, MD Qualified data center (§27-2500) Prince William County, VA Data center (§32-100) Somerville, MA Data center (§9.8.b) Vernal, UT Data center (§16.04.173) Wenatchee, WA Cryptocurrency mining; Data center (§10.08) ZONINGPRACTICE 6.22 AMERICAN PLANNING ASSOCIATION | page 5 Loudon County, Virginia Northern Virginia’s Data Center Alley, pri- marily clustered around Routes 7 and 267 in Loudon and Fairfax Counties is the larg- est data center market in the world (Fray and Koutsaris 2022). Its combined power consumption capacity is more than 1.6 giga- watts (GW), nearly twice as much as the next largest market. And within Data Center Alley, Loudon County has the highest concentra- tion of data centers. As of October 2021, data centers occupied more than 25 million square feet, with another 4 million square feet in development (LCDED 2022). Several important factors have driven demand for data center development in Loudon County. It is home to the Equinix internet exchange, one of the largest internet access points in the world and a successor to Metropolitan Area Exchange, East, the first U.S. exchange. The county has abundant (and redundant) fiber optic infrastructure, relatively cheap power, and sufficient water. Additionally, it has a high concentration of skilled technology workers and businesses that support the data center industry. By the year 2000, there was already an emerging data center cluster in Loudon County. However, the county did not define and regulate data centers as a distinct use in its zoning code until 2014 (ZOAM 2013- 0003). According to Acting Planning & Zoning Director James David, prior to this, the county defined data centers as commercial offices. The latest version of the county’s zoning ordinance permits data centers by right in Planned Office Park, Research and Development Park, Industrial Park, and General Industrial districts and as a special exception use in Commercial Light Industry districts. New data centers (without vested rights) must comply with a set of use-specific standards governing façade design, screen- ing of mechanical equipment, exterior lighting, pedestrian and bicycle facilities, and landscaping, buffering, and screening (§5-664). According to David, these standards are intended to improve the aesthetics of data centers, minimize visibility from nearby residential areas, and ensure continuous sidewalk and trail networks. Overall, they represent a light-touch approach that has, so far, worked well for a county with enor- mous demand for data centers and relatively modest competition for space from other commercial and industrial uses. However, in February 2022, county officials directed staff to research regulatory options to prevent new data centers in the EXAMPLES OF USE-SPECIFIC STANDARDS FOR DATA CENTERS AND CRYPTOCURRENCY MINING Jurisdiction Use-Specific Standards Alpharetta, GA Requires evidence of compliance with noise standards; specifies exterior lighting fixture design; establishes minimum building height; requires building façade design elements; establishes other fencing, screening, and landscaping requirements to minimize visibility from adjacent roads and properties (§2.7.2.1) Anne Arundel County, MD Establishes minimum lot size and setbacks; prohibits residences on the same lot; establishes limit on outdoor storage (§18-10-119) Fairfax County, VA Requires all equipment to be enclosed within a building; establishes maximum floor area by zoning district (§4102.6.A) Frederick County, MD Establishes criteria for reducing setbacks; specifies building design standards; specifies landscaping, screening, and buffering requirements; clarifies parking, loading, signage, and lighting standards; establishes criteria for private roads; establishes noise and vibration standards (§1-19-8.402) Moses Lake, WA Clarifies review process for business license; prohibits container storage; requires evidence of electrical utility approval; requires evidence of electrical permit and inspection; establishes environmental performance standards, addressing noise, heat, and electric and magnetic fields; limits amount of exposed equipment on facades (§18.74 ) Pitt County, NC Limits height; requires separation from sensitive uses; requires noise study and compliance with noise standards; requires underground wiring; requires security fencing and vegetative screening; requires evidence of electrical utility approval; clarifies signage standards; requires notification of abandonment (§8(UUUU)) Plattsburgh, NY Requires fire suppression and mitigation techniques; limits internal ambient temperature and the direct release of heat on colder days; establishes permissible noise levels (LL 6-2018) Prince George’s County, VA Requires building façade design elements; specifies exterior lighting fixture design; requires screening for security fencing and limits fence height; requires compliance with landscape manual; clarifies applicable off- street parking standard; clarifies signage standards; requires an acoustical study; specifies additional site, locational, and noticing requirements for facilities in rural residential districts (§27-5102(e)(4)(B)) Somerville, MA Establishes special review criteria related to aesthetic impacts and employment opportunities (§9.8.b) Vernal, UT Requires fencing and structural screening for electrical generators; requires noise mitigation plan for facilities near residential zones or existing hotels or motels (§16.20.250) Wenatchee, WA Clarifies review process for business license; prohibits container storage; requires evidence of electrical utility approval; requires evidence of electrical permit and inspection; clarifies blank wall limitation standards; requires an affidavit verifying operating sound levels (§18.48.310) ZONINGPRACTICE 6.22 AMERICAN PLANNING ASSOCIATION | page 6 Route 7 corridor. While data center demand remains high in this area, the county’s comprehensive plan designates most of this corridor as Suburban Mixed Use, which envisions a compact, pedestrian-friendly mix of commercial, residential, cultural, and recreational uses. Furthermore, the existing electricity network infrastructure is insuf- ficient to accommodate the existing demand for new data centers (LCDED 2022). The county is working on its first com- plete overhaul of its zoning code since 1993. And it intends to incorporate any new regu- lations for data centers into the new code, which officials hope to adopt by the end of 2022. Missoula County, Montana In April 2019, Missoula County, Montana, adopted an interim zoning resolution that established a cryptocurrency mining overlay (Resolution No. 2019-026). The county had one large cryptocurrency mine already, and its low electricity rates and cool climate made it an attractive area for prospective miners. While a few other jurisdictions had already defined cryptocurrency mining in their zoning codes, Missoula County appears to be the first to explicitly position its zoning approach as a response to climate change. According to county planner Jennie Dixon, aicp, local officials originally took an interest in regulating cryptocurrency mining as a distinct use after multiple complaints of noise from cooling fans at an existing Bitcoin mine operating out of a former sawmill in unincorporated Bonner. Soon, though, the county expanded its focus to include energy consumption and electronic waste. Montana law only authorizes interim zoning in the case of an emergency involving “public health, safety, morals, or general welfare” (§76-2-206). Dixon says the Inter- governmental Panel on Climate Change’s 2018 Special Report on Global Warming of 1.5 ° C helped justify climate change as a local emergency that warranted interim zon- ing to mitigate greenhouse gas emissions (and other potential environmental impacts) from cryptocurrency mining. The interim zoning regulations defined cryptocurrency mining as a distinct use and created a Cryptocurrency Mining Overlay Zone, mapped to the entire unincorporated geographic extent of the county (which includes some un-zoned areas). The overlay restricted cryptocurrency mining opera- tions to industrial districts and required operators to obtain a discretionary use per- mit if the mine was adjacent to a residential district or within 500 feet of a residential property boundary. These regulations also required all mining operations to verify that all electronic waste be handled by a licensed recycling firm and that all electricity use be offset by new renewable energy production. Caroline Lauer, the county’s Sustain- ability Program Manager, stresses the importance of this last requirement. If cryptocurrency miners purchased existing supplies of renewable energy, it could actu- ally displace existing utility customers to dirtier sources. While most of the county’s electricity comes from hydropower, coal accounts for much of the remainder. Missoula County’s 2016 Growth Policy plan includes an objective to “reduce the county’s contribution to climate change” (4.1) and lists policies that promote alterna- tive energy development (4.1.3) and reduce energy use and waste generation as imple - mentation actions (4.1.6). A day before it adopted the interim cryptocurrency mining regulations, the county further strengthened its policy rationale by adopting a joint com- mitment with the City of Missoula to achieve 100 percent clean electricity use by 2030. County officials extended the interim zoning for another year in 2020 before adopt- ing the same regulations as a permanent zoning amendment in March 2021 (§1.04 The former Bonner sawmill in Missoula County, Montana, was once home to the HyperBlock cryptocurrency mine.Google EarthThe heart of Northern Virginia’s Data Center Alley in Ashburn, Virginia.Google Earth ZONINGPRACTICE 6.22 AMERICAN PLANNING ASSOCIATION | page 7 Cover: iStock.com/gorodenkoff VOL. 39, NO. 6 The American Planning Association will lead the way to equitable, thriving communities by creating unique insights, as well as innovative and practical approaches that enable the planning community to anticipate and successfully adapt to the needs of a rapidly changing world. Zoning Practice (ISSN 1548–0135) is a monthly publication of the American Planning Association. Joel Albizo, fasae, cae, Chief Executive Officer; Petra Hurtado, phd, Research Director; David Morley, aicp, Editor. Subscriptions are available for $95 (U.S.) and $120 (foreign). Missing and damaged print issues: Contact APA Customer Service (312-431-9100) within 90 days of the publication date. ©2022 by the American Planning Association, 205 N. Michigan Ave., Suite 1200, Chicago, IL 60601–5927; planning.org. All rights reserved. No part of this publication may be reproduced or utilized in any form or by any means without permission in writing from APA. Printed on recycled paper, including 50-70% recycled fiber and 10% postconsumer waste. REFERENCES AND RESOURCES Dunbar, Courtney and Robert Bonar. 2021. “Siting Next-Generation Data Centers.” Area Development, Q2. bit.ly/390dyJ3 Evans-Cowley, Jennifer. 2002. Telecom Hotels: A Planners Guide. PAS Report No. 505. Chicago: American Planning Association. bit.ly/39Dezaa Fray, Andrew and Bobby Koutsaris. 2022. 2022 Global Data Center Market Comparison. Chicago: Cushman & Wakefield. cushwk.co/3P8JOdB Gomez, Alexsandra and Joseph DeAngelis. 2022. Digitalization and Implications for Planning. Chicago: American Planning Association. bit.ly/3KUP1lT International Energy Agency (IEA). 2021. “Data Centres and Data Transmission Networks.” Tracking Report, November. bit.ly/3FsMSwR Loudon County [Virginia] Department of Economic Development (LDED). 2022. Loudon County Data Center Land Study. bit.ly/3P7DYt0 Missoula (Montana), County of. 2021. “Cryptocurrency Mining.” bit.ly/3PbSr72 Mytton, David. 2021. “Data Centre Water Consumption.” NPJ Clean Water, 4(11). bit.ly/3wjRUaR Obando, Sebastian. 2022. “Cryptocurrency Bans Fuel US Data Center Construction.” Construction Dive, February 16. bit.ly/3w7aG6t Rozen, Jacob. 2020. “Poor Business Model, Not COVID-19 Behind Hyperblock Early Struggles.” Coingeek, December 23. bit.ly/37uFHYp Tarczynska, Kasia. 2016. Money Lost to the Cloud: How Data Centers Benefit From State and Local Government Subsidies. Washington, D.C.: Good Jobs First. bit.ly/398mn3m Sowry, David, Jani Dharmesh, Don Duet, Frank Yan, Harry Smeenk, James Young, Phillip Marangella, and Robert Bunger. 2018. TIA Position Paper: Edge Data Centers. Arlington, Virginia: Telecommunications Industry Association. bit.ly/3N3U58Y University of Cambridge. 2022. “Cambridge Bitcoin Electricity Consumption Index.” bit.ly/38hj1v1 & §5.05). According to Dixon, the Bonner mine ceased operations during the interim zoning period, but not because of the county’s zoning. It declared bankruptcy two days after the “Black Thursday” Bitcoin crash in March 2020, leaving the tribal- owned independent power producer that provided its electricity with a $3.7 million unpaid bill (Rozen 2020). CONCLUSIONS The rapid rise in data center development has coincided with dramatic decreases in the costs of producing solar and wind power. This, in combination with a growing trend toward clean power commitments among technology companies, has blunted some of the climate impacts of an increased demand for data storage and processing. The increased digitalization of life virtually guarantees that data centers will continue proliferating in strategic locations across the country (Gomez and DeAngelis 2022). Soon, communities may start seeing a sharp increase in interest in very small edge data centers that could fit in underutilized commercial spaces or even be collocated with other telecommunications infrastruc- ture, such as small cell facilities, in public rights-of-way (Sowry et al. 2018). The future of cryptocurrency mining facilities is less certain. Bitcoin and other energy-intensive cryptocurrencies are fac- ing social pressure to transition to more energy-efficient transaction verification methods, and several existing cryptocurren- cies already use these methods. However, we are still at the very beginning of the cryp- tocurrency story. While this form of currency currently exists primarily as a speculative investment vehicle, this could change rapidly if valuations stabilize and large numbers of goods and service providers accept crypto- currencies for payment. Not every community will see the value in defining data centers or cryptocurrency mines as distinct uses in their zoning codes. Nevertheless, doing so can give local juris- dictions a leg up when it comes to signaling preferences to developers and operators and minimizing or mitigating potential adverse impacts. ABOUT THE AUTHOR David Morley, aicp, is a research program and QA manager with the American Planning Association and editor of Zoning Practice. ZONING PRACTICEAMERICAN PLANNING ASSOCIATION205 N. Michigan Ave.Suite 1200Chicago, IL 60601–5927Creating Great Communities for AllHOW DOES YOUR ZONING TREAT DATA CENTERS AND CRYPTOCURRENCY MINES?6 ZONING PRACTICE Unique Insights | Innovative Approaches | Practical Solutions OCTOBER 2025 | VOL. 42, NO. 10 The Physical Footprint of Artificial Intelligence In this Issue: What Are the Physical Needs of AI? | How Is AI Infrastructure Regu- lated (or Not)? | What Should Planners Be Thinking About? | Where Can Planners Learn More? Zoning Practice | American Planning Association | October 2025 2 The Physical Footprint of Artificial Intelligence By Charlie Nichols, aicp Every time you ask ChatGPT, Gemini, or Claude a question, you are tapping into a sprawling, power-hungry network of machines. Somewhere, a data center’s processors are whirring, fans are spinning, and megawatts of electricity are flowing. Artificial intelligence (AI) may feel vir- tual, but its footprint is intensely physical. Behind every chatbot interaction, predic- tive algorithm, or autonomous system lies a vast network of data centers, power generators, and electricity transmission and distribution infrastructure. As vast as it is now, the demand for computing power is growing at an exponential rate, and local zoning is on the front lines. This issue of Zoning Practice explores the physical effects of AI deployment and highlights core considerations for local planning and zoning. It begins with a sum- mary of the land use characteristics of the system of data centers that host and serve contemporary AI models before highlight- ing noteworthy regulatory approaches and areas of opportunity for zoning updates and land use decision-making processes. Data center infrastructure in the United States, 2025 (Credit: NREL) Zoning Practice | American Planning Association | October 2025 3 What Are the Physical Needs of AI? When we think about artificial intelli- gence, we often imagine abstract ideas or algorithms, software, or maybe a chat assistant or a robot. But AI is deeply phys- ical. It runs on powerful hardware that lives in large buildings, draws enormous amounts of electricity, and requires robust infrastructure to keep it cool and opera- tional. These needs are shaping land use decisions in ways many communities have never dealt with before. AI Lives in Data Centers The primary home of AI is the data center. These are large, sometimes windowless, buildings filled with servers, networking equipment, and backup systems. While some are sleek and high-tech, many look like simple warehouses. But inside, the technology is anything but simple. AI workloads require far more com- putational power than traditional cloud computing. That means more servers packed with graphics processing units (GPUs), which are optimized for machine learning tasks. These GPUs are energy-in- tensive and generate a significant amount of heat (Shehabi et al. 2024; Casey 2025). This is why the design, location, and infrastructure of data centers have become such a big deal. For example, Meta’s Altoona, Iowa, data-center campus has more than five million square feet of space and is still growing (Miller 2022). Data centers themselves fall into sev- eral distinct categories. Edge or micro facilities are the smallest, often modular container-sized enclosures ranging from a few hundred to a few thousand square feet. Enterprise data centers, typically operated by corporations or universities, can range from about 5,000 to 50,000 square feet, sometimes larger. Colocation facilities lease space to multiple ten- ants and often fall between 50,000 and 600,000 square feet, with many averaging around 150,000 square feet. At the largest scale are hyperscale data centers, typically built by major cloud or AI providers, which can easily reach hundreds of thousands of square feet per building and exceed one million square feet across a campus (Zhang 2023). While many forecasts focus on power demand rather than square footage, it is possible to translate one into the other. Deloitte estimates that AI-driven data centers could require up to 123 gigawatts (GW) of capacity in the U.S. by 2035, com- pared to roughly 4 GW today (Stansbury et al. 2025). Real-world projects suggest that every megawatt of IT load requires between 5,000 and 12,000 square feet of total building area. Applying that ratio to 123 GW implies a national buildout of 615 million to 1.48 billion square feet of data center space, equivalent to about 22 to 53 square miles. Land use estimates point in a similar direction, with recent proj- ects averaging 0.5 to 1.5 acres per MW, which would translate to roughly 96 to 288 square miles of U.S. land devoted to AI-related data center campuses by 2035 (Stansbury et al. 2025). A proposed 612- acre hyperscale data center campus in Cedar Rapids, Iowa (Credit: QTS) AI Needs Lots of Electricity Power demand is one of the most crit- ical limiting factors in scaling AI. The U.S. Department of Energy’s Secretary of Energy Advisory Board notes that legacy hyperscale data centers have typically connected at 20–50 megawatts (MW), but utilities are now receiving AI-driven connection requests for single campuses of 300–1,000 MW (2024). To put the low end of that new range in context, a 300 MW facility running around the clock would consume about 2.6 terawatt-hours a year—roughly the annual electricity use of 250,000 U.S. homes (calculated Zoning Practice | American Planning Association | October 2025 4 with the U.S. EIA average of 10,500 kWh per household). These unprecedented loads are forcing planners, utilities, and regulators to rethink siting, transmission capacity, and community-impact mitiga- tion. This demand is driving data centers to locate near existing transmission infra- structure, substations, or power plants. In some cases, new substations or trans- mission lines are being proposed just to support AI infrastructure. Local planners are being asked to approve not just build- ings, but energy projects with regional impacts. There is also growing concern about the climate impacts of AI. Researchers estimate that the cumulative carbon emis- sions from AI models could reach 3.66 to 8.72 million tons in the U.S. alone—the equivalent of driving an average gaso- line-powered car nine to 22 billion miles (Ding et al. 2025; USEPA 2024). This has led to pressure for data centers to run on renewable energy, adding another layer of land use complexity as solar or wind farms are proposed nearby or colocated together with data centers. AI Needs Water and Cooling All that power generates heat, and that heat has to go somewhere. Most data centers use a combination of air- and watercooling systems. Some of the largest AIfocused facilities can consume hundreds of thousands of gallons of water per day for evaporative cooling (Lei et al. 2025; Shehabi et al. 2024; Selsky 2022). That’s raising concerns in water-scarce regions or places where water infrastructure is already stretched thin. For example, in The Dalles, Oregon, a dispute between Google and the city over water use became national news when the city council approved a water agree- ment to support Google’s data center expansion, despite local concerns about long-term water availability (Selsky 2022). Water and cooling infrastructure also raise siting questions. Should data centers be allowed in areas with limited water sup- ply? What happens when a tech company becomes one of the largest users of municipal water? These questions are starting to reach planning commissions and city councils. AI Needs Fiber and Connectivity Finally, AI infrastructure depends on high- speed fiberoptic connections. Training models and delivering AI services both require fast, reliable data transmission. This can drive the need for new fiber lines, telecom infrastructure, or even small-cell installations in rural or suburban areas (RVA LLC 2025; Walker 2024). It’s not just big cities seeing these investments. Some rural areas are gaining interest from AI developers because they offer space, lower land costs, and coop- erative local governments—provided they can offer fiber access and a willing utility partner. How Is AI Infrastructure Regulated (or Not)? If your city or county does not already have a data center, just wait. The odds are increasing that a tech company, or the utility that serves them, will soon come knocking. Yet most local governments are not fully prepared to regulate AI infra- structure. In many places, the regulatory framework is either nonexistent or built for a different era of technology. Zoning Codes Rarely Mention AI or Data Centers Many zoning codes still make no explicit reference to “artificial intelligence” or even to “data centers.” Where definitions are 1,410.3 9.4 Golf Courses 1,108.3 7.4 Golf Courses 853.8 5.7 Golf Courses 532.3 3.5 Golf Courses 461.1 3.1 Golf Courses 0 200 400 600 800 1,000 1,200 1,400 1,600 Council Bluffs, IA Mayes County, OK Berkeley County, SC Papillion, NE The Dalles, ORAnnual Water Withdrawal (Millions of Gallons)Google Data Center Locations Top-five U.S. Google data centers by annual water withdrawals, 2024 (Credit: Google’s 2025 Environmental Report) Zoning Practice | American Planning Association | October 2025 5 absent, planners may choose to slot these facilities into broad buckets such as ware- housing, light-industrial, or public-utility uses, even though the buildings may be packed wall-to-wall with servers instead of pallets. Yet these facilities behave very dif- ferently from the categories they’re often shoehorned into, and there are many reasons why local governments may want to specifically define data center uses (Morley 2022). Their continuous operation demands megawatts of electricity and, in many climates, hundreds of thousands of gallons of cooling water per day; the equipment generates heat and noise; and the employment footprint is minimal. When such impacts are overlooked, commu- nities can be blindsided—as happened in Prince William County, Virginia, where approval of a massive datacenter corridor sparked backlash over noise, power deliv- ery, and land use compatibility. Recognizing this mismatch, an increasing number of jurisdictions have begun to write data-center-specific rules. Loudoun County, Virginia, imposes façade, screening, lighting, and pedes- trian-connectivity standards on by-right data centers to blunt visual impacts while leveraging their tax base (§4.06.02). Prince William County uses a Data Center Opportunity Zone Overlay to funnel proj- ects to infrastructure-served parcels and require design review (§32-509). Missoula County, Montana, offers a different model. The county’s ordinance, crafted for crypto- currency mines, confines those operations to industrial zones and requires them to offset 100 percent of their electricity use with renewable energy (§5.10 ). Because cryptocurrency mines and large-scale data centers both run continuously, draw high-density power, and employ few on-site workers, planners can adapt the same toolkit—clear land use definitions, targeted overlay districts, and energy-fo- cused performance standards—to data centers when communities want compa- rable safeguards. Looking ahead, AI training clusters dwarf the loads discussed in 2022, with utilities now fielding single-campus inter- connection requests of 300 MW and more. The zoning fundamentals remain the same, but the stakes are higher. Without proactive definitions, locational criteria, and impact standards, local governments risk conceding critical decisions about land, water, and grid capacity to devel- opers’ timetables rather than community goals. Data Center Alley in Loudoun County, Virginia (Credit: Gerville/ iStock/Getty Images Plus) Many AI Facilities Are Allowed by Right In areas that do allow data centers by right, local officials often have little authority to influence their design or sit- ing (Morley 2022). Developers may be able to build massive facilities with only admin- istrative approval. If the project complies with the basic zoning and building code, it can move forward, even if it brings signifi- cant impacts to neighboring properties or the local infrastructure system. This hands-off, by-right approach can leave neighbors in the dark when a cam- pus that draws 100 MW or more of power is permitted the same way a warehouse is. Such facilities may also require hun- dreds of thousands of gallons of cooling water per day and generate continuous low-frequency noise from chillers, pumps, and backup generators (Van Geet and Sickinger 2024). Without a public-hearing trigger, residents may not learn what is coming until the bulldozers roll. That said, relying on discretion- ary use permits alone is not a perfect fix. Case-by-case approvals can introduce uncertainty, increase timelines, and dupli- cate reviews that utilities already perform when they decide whether to supply the necessary electricity and water. A more balanced strategy is to embed objective, use-specific standards (e.g., caps on sound at the property line, requirements for renewable-energy procurement, and Zoning Practice | American Planning Association | October 2025 6 water-recycling targets) directly into the zoning code. Guidance from the Urban Land Institute shows how clear definitions, overlay districts, and measurable perfor- mance thresholds can give developers predictability while still protecting commu- nity interests (Miet 2024). By pairing these standards with early coordination among planners, utilities, and residents, commu- nities can address local impacts without resorting to duplicative or open-ended dis- cretionary reviews. Infrastructure Approvals May Be Handled Separately Adding to the complexity, the infrastructure needed to support AI such as transmis- sion lines, substations, power generation facilities, battery energy storage. and fiber installations is often regulated under dif- ferent frameworks. Utilities may have their own review and siting authority at the state level, which can bypass local land use processes entirely. Large solar or wind projects, for exam- ple, are pre-empted from local control in more than 20 U.S. states, leaving local governments to vet the data-center build- ing, while the power generation facility that feeds it is debated elsewhere (Gomez and Morley 2023; Morley 2025). Fragmented approvals make it hard for planners to tally cumulative effects such as substations, access roads, or groundwater withdrawals. Battery-energy-storage systems (BESS) create another layer of complexity, and a clear trend of data centers colocat- ing BESS on-site is accelerating (ZincFive 2024). Some states exempt utili- ty-scale BESS that are colocated with generation assets, while others treat them as industrial equipment needing only an electrical permit. Where local authority does apply, recent guidance recommends clear definitions, district regulations, and objective safety standards, thermal-run- away monitoring, minimum setbacks, and emergency-response plans to avoid ad-hoc hearings (Ross and Vadali 2024). Developers are now bundling data centers with on-site renewables and stor- age in microgrid “energy parks,” aiming to bypass long interconnection queues and control energy costs. Recent proj- ects in Texas and Virginia pair hundreds of megawatts of generation and storage with adjacent server halls, creating hybrid campuses that straddle state energy-facil- ity review, regional transmission rules, and local zoning (DiGangi 2025). To keep pace, planners can identify jurisdictional triggers early, embed measurable performance standards (e.g., noise caps, screening, or renewable-energy sourcing) in their codes, The Eland Solar- plus-Storage Center in Kern County, California (Credit: The Desert Photo/iStock/Getty Images Plus) Zoning Practice | American Planning Association | October 2025 7 and coordinate with utilities so local and state reviews proceed on aligned time- lines. Environmental Review Is Inconsistent Environmental review of AI infrastructure also varies widely. In states that require environmental impact statements (EIS), large-scale data centers may undergo detailed scrutiny. But in states without EIS laws, or for smaller projects, there may be minimal analysis of water use, energy con- sumption, or greenhouse gas emissions (Morris 2024). Even where review is required, the focus may be on the building itself, rather than the full ecosystem of impacts. For example, if a local code does not require review of off-site power infrastructure or supporting utility upgrades, critical issues related to energy delivery, environmental impact, or long-term capacity may fall through the cracks. Local Governments Are Starting to Catch Up Local governments are no longer standing still while hyperscale campuses spring up at the edge of town. Since 2023, a wave of city councils, county boards, and planning commissions have begun mov- ing data centers out of catch-all industrial categories and into their own, better-de- fined regulatory boxes. Some jurisdictions, such as Atlanta, now require special-use permits tied to energy, water, and noise studies (Ordinance 25-O-1063 ). Others, such as Cedar Rapids, Iowa, leverage community-benefit agreements to ensure local reinvestment when a project wins approval (Pratt 2025). Approaches vary, but the trend is unmistakable: Communities are adopting objective, use-specific standards rather than relying solely on ad-hoc discretionary permits. Some ordinances steer projects into infrastructure-served corridors, others set caps on sound and water use, and a growing number link approvals to renew- able energy procurement or on-site battery storage. Table 1 highlights seven recent examples illustrating the breadth of new zoning language, overlay districts, and design guidelines that together show local governments are indeed catching up. Table 1. Examples of Recent Local Regulatory Updates for Data Centers Jurisdiction How it regulates data-center impacts Atlanta, GA Requires a special-use permit for every new data center and empowers the city council to review water-consumption, energy- efficiency, and noise-mitigation plans (Ordinance 25O1063, 2024) Brainerd, MN Prohibits data centers unless the planning commission approves a conditional-use permit that addresses cooling noise and utility demand (Ordinance No. 1581, 2025) Chandler, AZ Adds a data center use category; limits the use to Planned Area Development zones and sets size, generator-testing and water-recycling standards (Ordinance No. 5033, 2022) Tempe, AZ Requires a water use plan and enhanced setbacks next to homes and schools, and “innovation hubs” (Ordinance No. O2025-23, 2025) Phoenix, AZ Defines “data center,” restricts locations, and introduces design standards such as façade articulation and noise studies (Ordinance G-7396 , 2025) Sugar Grove, IL Creates a dedicated district with height limits, façade screening, and a master-utility-plan requirement (Ordinance No. 2022-1206B, 2022) Frederick County, MD Establishes an overlay zone that limits where data centers can be built (Bill No. 25-05, 2025) What Should Planners Be Thinking About? Artificial intelligence may sound futuristic, but the decisions that shape its physical footprint are being made today. Local governments that wait too long to prepare may find themselves reacting to projects rather than guiding them. So what should planners be thinking about now? Think About Scale AI infrastructure often hides in plain sight until its true footprint emerges. What looks like a single “warehouse” can blossom into a portfolio buildout—multiple server Zoning Practice | American Planning Association | October 2025 8 halls, two substations, a battery yard, and a 30-inch water main, all staged over a decade (USDOE SEAB 2024). To avoid approving these megaprojects one slice at a time, some jurisdictions now demand a phased master plan up front. For example, Loudoun County, Virginia, requires every data-center rezoning to include a “Data Center Development Plan” showing the full buildout of power feeds, cooling infrastruc- ture, and utility corridors before the first site plan is approved (2025). Regional utilities are following suit by running scenario-based load models to test whether transmission and groundwa- ter supplies can keep up. A 2024 white paper by Energy + Environmental Eco- nomics describes how such models informed Portland (Oregon) General Electric’s latest integrated-resource plan and helped local planners identify future right-of-way corridors for two new 230-kV lines (Riu et al. 2024). By asking for phased utility exhibits and participating in utility load-growth scenarios, planners can make sure each new server hall fits into a sys- tem-wide picture rather than becoming an isolated surprise. Think About Alignment With Your Plans Many comprehensive plans still treat “technology infrastructure” as an after- thought, yet data-center proposals are now shaping decisions on land sup- ply, energy policy, water allocation, and broadband. Start by inventorying where AI-related facilities touch existing plan elements—utilities, environmental steward- ship, economic development—and flag the gaps. One emerging best practice is to link data-center approvals directly to com- munity climate goals. Embedding such benchmarks in comprehensive plans or codes gives planners clear decision crite- ria and ensures that new AI infrastructure advances, rather than conflicts with, local resiliency objectives. Plans can also weave data-center growth into broadband and workforce strategies. The U.S. Department of Ener- gy’s 2024 report on AI infrastructure recommends that local governments coor- dinate land-use designations with state broadband-expansion maps so that fiber corridors serving data centers double as backbone routes for underserved neigh- borhoods (USDOE SEAB 2024). Aligning these layers up front helps planners negotiate public-benefit clauses—such as dark-fiber setasides or training programs, rather than scrambling for concessions late in the process. Updating your plan first and then adopting measurable standards that flow from it gives applicants clarity, while ensur- ing projects advance the community’s long-term vision. Think About Infrastructure Capacity AI campuses can overwhelm local utilities faster than many other land uses. Virgin- ia’s Joint Legislative Audit and Review Commission estimates that data centers will require 11 gigawatts (GW) of new elec- tric generation and transmission in that state alone by 2035, roughly one-third of Dominion Energy’s entire current system (VJLARC 2024). National modeling by Energy + Environmental Economics shows a similar surge, with some balancingareas seeing load grow 25 percent in a single decade under an “AI-high” scenario (Riu et al. 2024). Water systems face parallel stress. At Google’s complex in The Dalles, Oregon, public records show cooling demand could top one-quarter of the city’s cur- rent supply, prompting a 2023 agreement that pauses future phases unless new wells come online (Selsky 2022). Quincy, Washington, responded to similar pres- sures by creating a special water rate class and meter fee for data centers to fund infrastructure upgrades (2025). These examples point to tools planners can Many comprehensive plans still treat “technology infrastructure” as an afterthought, yet data center proposals are now shaping decisions on land supply, energy policy, water allocation, and broadband. Zoning Practice | American Planning Association | October 2025 9 adopt: cumulative-demand studies embedded in utility master plans, tiered rate structures that recover capital costs, and permit conditions that link new con- struction to confirmed water-capacity projects. Electric and water systems are only part of the picture. Broadband providers may need additional conduit banks, and public works departments often discover that construction traffic surpasses road- design volumes. Objective, use-specific standards, such as requiring a utilityinfra- structure plan that maps ultimate substations, mains, and fiber routes, plus haul-route and pavement-repair agree- ments, give planners leverage without duplicating state or utility reviews. Think About Cumulative Impacts A single 30 MW data center can feel benign, yet clusters of 10 or more along one corridor may push peak electric load past a gigawatt, double truck traffic during construction, and raise ambient sound by up to 10 dBA at nearby homes (VJLARC 2024). Project-by-project review often misses these system-level effects, so several jurisdictions now require applicants to look beyond their parcel lines. Clustering can also amplify benefits The Three Mile Island nuclear power plant in Middleton, Pennsylvania, which is coming back online to power Microsoft data centers (Credit: gsheldon/ iStock Editorial/ Getty Images Plus) if managed deliberately. Developers in Texas and Virginia now pair multiple server halls with a shared microgrid that combines on-site solar, wind, and battery storage—an “energy-park” model that eases interconnection delays and helps regions meet renewable-energy goals (DiGangi 2025). By mapping preferred corridors for both data centers and their supporting infrastructure, planners can steer growth to areas where capacity, compatibility, and community returns align. Think About Equity and Community Benefits Data-center projects promise major capital investment but generate few long-term jobs and can offload noise, truck traffic, and resource use onto nearby neighbor- hoods. Additionally, new cost analyses show that ordinary ratepayers are already footing most of the bill for AI’s voracious appetite for electricity. Monitoring Analytics, the independent market monitor for PJM Interconnection, the largest regional transmission organi- zation in the U.S., calculated that between 2024 and 2025 data-center electricity demand added about $25 to the typical household’s monthly bill (Biryukov 2025). PJM now projects that AI and data-center Zoning Practice | American Planning Association | October 2025 10 demand will double the region’s energy use by 2033, whereas growth would have been only 15 percent by 2040 without new campuses (JLARC 2024). In response to this and other similar projections of effects on ratepayers, law- makers in New Jersey (AB 5466), Oregon (HB 3546), and other states have intro- duced bills or tariffs to place data centers in a separate rate class or require them to “bring their own clean power,” so every- day customers are not forced to subsidize the electricity needs of trillion-dollar tech companies (Levy 2025). More commu- nities are also moving to tie approvals to arrangements that deliver measurable local benefits. For example, Cedar Rapids, Iowa, required QTS to sign a community benefits agreement (CBA) that will return about $18 million over 20 years for workforce training, broadband expan- sion, and green-infrastructure projects (Pratt 2025). Legal guidance stresses clear milestones, third-party verification, and enforcement clauses to keep such agree- ments credible (Eisenson 2023). Meanwhile, Quincy, Washington, cre- ated a special water rate class for data centers in 2024, adding higher volumetric charges and meter fees earmarked for new wells and main upgrades. Targeted surcharges turn one user’s high demand into system-wide resilience. By weaving CBAs and host-com- munity fees into zoning approvals or development agreements, planners can ensure that AI infrastructure acts as a catalyst for broader community gain rather than an enclave of private benefit. Where Can Planners Learn More? As artificial intelligence infrastructure expands, planners have a growing need to stay informed about what these facilities are, how they function, and how to plan for them thoughtfully. The good news is that several helpful resources already exist, and more are emerging every year. Follow the Energy Many AI-related land use challenges stem from energy demand. That means energy planning organizations are a good place to start. Resources from the U.S. Depart- ment of Energy, National Renewable Energy Laboratory, and Lawrence Berke- ley National Laboratory offer insights into data center energy use, grid impacts, and cooling technologies (Shehabi et al. 2024; USDOE SEAB 2024; Van Geet and Sick- inger 2024). State and regional energy offices are also useful partners. They can help plan- ners understand energy trends, forecasted demand, and opportunities to align AI-re- lated development with state energy goals. Watch the Water Water use is another key issue, especially in places facing drought or groundwater depletion. Reports from the U.S. Environ- mental Protection Agency, as well as local water utilities and watershed management agencies, can help assess water-related impacts of AI infrastructure. Planners can also look to academic and journalistic research on water use in cooling systems, which varies significantly based on the type of cooling and climate zone (Berreby 2024). Track Technology and Land Use Trends For a broad view of how technology affects land use, the Lincoln Institute of Land Policy and the Urban Land Institute have both published helpful materials. These organizations explore how emerg- ing technologies from AI to autonomous vehicles are reshaping cities, infrastruc- ture, and land markets. A North Dakota data center using nonconductive fluid to cool servers rather than air or water cooling systems (Credit: halbergman/E+) Zoning Practice | American Planning Association | October 2025 11 Local case studies can also be instructive. Some jurisdictions have started sharing lessons learned from planning for large-scale data centers or tech cam- puses. For example, Loudoun (2024; 2025) and Fairfax (2024) Counties in Virginia offer planning documents and staff reports that shed light on real-world challenges and solutions. Build Cross-Sector Relationships Planning for AI infrastructure requires col- laboration. It touches on land use, utilities, economic development, and environmen- tal protection. Building relationships with energy providers, water utilities, economic development groups, and regional plan- ning agencies can help planners spot opportunities and anticipate challenges. Conferences like the American Plan- ning Association’s National Planning Conference, Grid Forward, or Smart Cities Connect often include sessions on tech- nology infrastructure. These events are a great way to hear from peers and industry experts. AI infrastructure is no longer a far- off idea; it’s already shaping land use decisions in communities across the country. For planners, this presents both challenges and opportunities. By under- standing what AI infrastructure is, what it requires, and how it fits into broader plan- ning goals, local governments can prepare for development that is sustainable, equi- table, and forward-looking. As with many emerging trends, the best path forward is to stay curious, build partnerships, and think holistically. AI may be powered by algorithms, but the future it creates will depend on human decisions, including the choices planners make today. References and Resources Berreby, David. 2024. “As Use of AI Soars, So Does the Energy and Water It Requires.” Yale Environment 360, February 6. Biryukov, Nikita. 2025. “Power Companies Warn Lawmakers About Their Plans to Tackle Rising Bills.” New Jersey Monitor, April 25. Casey, Evan. 2025. “Microsoft Built Five Data Center Campuses in This Iowa City. Here’s What Wisconsin Can Expect.” Wisconsin Public Radio, May 15. DiGangi, Diana. 2025. “Microgrid ‘Energy Parks’ Could Ease Strain from Rising Power Demand, Report Says.” Utility Dive, July 23. Ding, Zhaohao, Jianxiao Wang, Yiyang Song, Xiaokang Zheng, Guannan He, Xiupeng Chen, Xiupeng Chen, Tiance Zhang, Wei-Jen Lee, and Jie Song. 2025. “Tracking the Carbon Footprint of Global Generative Artificial Intelli- gence.” The Innovation 6(5): 100866. Eisenson, Matthew. 2023. “Experts Identify Best Practices for Negotiating and Drafting Community Benefits Agreements.” Climate Law, September 27. Fairfax (Virginia) Department of Planning Devel- opment, County of. 2024. Data Centers Report and Recommendations. Gomez, Alexsandra, and David Morley. 2023. Solar@Scale: A Local Government Guidebook for Improving Large-Scale Solar Development Outcomes. Chicago: American Planning Associ- ation; Washington, DC: International City/County Management Association. Lei, Nuoa, Jun Lu, Arman Shehabi, and Eric Masanet. 2025. The Water Use of Data Center Workloads: A Review and Assessment of Key Determinants. Berkeley, CA: Lawrence Berkeley National Laboratory. Levy, Marc. 2025. “As Electric Bills Rise, Evidence Mounts That Data Centers Share Blare. States Feel Pressure to Act.” Associated Press, August 8. Loudoun (Virginia), County of. 2024. “Data Cen- ter Growth and Energy Constraints.” Board of Supervisors Transportation and Land Use Com- mittee Information Item, June 20. Loudoun (Virginia), County of. 2025. Data Center Standards & Locations. Miet, Hannah. 2024. “Local Guidelines for Data Center Development.” Washington, D.C.: Urban Land Institute. Miller, Rich. 2022. “The New MegaCampuses: The World’s Largest Data Center Projects.” Data Center Frontier, November 1. About the Author Charlie Nichols, aicp, is the Director of Planning and Development for Linn County, Iowa. He leads a 15-person department and has written pioneering zoning ordinances for utility-scale solar, nuclear energy, and hyperscale data centers. Nichols received his master’s degree in urban and regional planning from the University of Iowa and has been working in the field of planning for over 10 years. Outside of work, he enjoys tending to his backyard chickens and working on home renovation projects with his wife and three children. Zoning Practice | American Planning Association | October 2025 12 American Planning Association Creating Great Communities for All Morley, David. 2022. “Zoning for Data Centers and Crypto- currency Mining.” Zoning Practice, June. American Planning Association. Morley, David. 2025. “Wait, Who Approves Large-Scale Solar Siting?” APA Blog, March 3. Morris, Jackson. 2024. “Data Centers Gobbling Up Existing Nukes Threatens Grid Decarb Goals.” National Resources Defense Council Expert Blog, July 11. Pratt, Richard. 2025. “Cedar Rapids Council Approves Devel- opment Agreement for QTS Data Center Project.” Corridor Business Journal, January 30. Prince William (Virginia) Planning Office, County of. 2022. DPA2021-0020: Data Center Opportunity Zone Overlay Dis- trict Comprehensive Review. Quincy (Washington), City of. 2025. Rate Resolution 25-709. Riu, Isabelle, Dieter Smiley, Stephen Bessasparis, and Kushal Patel. 2024. Load Growth Is Here to Stay, But Are Data Cen- ters? San Francisco: Energy + Environmental Economics. Ross, Brian, and Monika Vadali. 2024. “Battery Energy Stor- age Systems.” Zoning Practice, March. RVA LLC. 2025. “The Underappreciated Need to Enable AI and Data Center Growth.” Washington, DC: Fiber Broadband Association. Selsky, Andrew. 2022. “Oregon City Drops Fight to Keep Google Water Use Private.” Associated Press, December 15. Shehabi, Arman, Sarah J. Smith, Alex Hubbard, Alex Newkirk, Nuoa Lei, Md Abu Bakar Siddik, Billie Holecek, Jonathan Koomey, Eric Masanet, and Dale Sartor. 2024. 2024 United States Data Center Energy Usage Report. Berkeley, CA: Lawrence Berkeley National Laboratory. Stansbury, Martin, Kelly Marchese, Kate Hardin, and Carolyn Amon. 2025. “Can U.S. infrastructure Keep Up With the AI economy?” Deloitte Insights, June 24. U.S. Department of Energy, Secretary of Energy Advisory Board (USDOE SEAB). 2024. “Recommendations on Powering Arti- ficial Intelligence and Data Center Infrastructure.” U.S. Energy Information Administration. 2024. Use of Energy Explained: Electricity Use in Homes. U.S. Environmental Protection Agency (USEPA). 2024. Green- house Gas Equivalencies Calculator. Virginia Joint Legislative Audit and Review Commission (VJLARC). 2024. Virginia Data Center Study: Electric Infra- structure and Customer Rate Impacts. Van Geet, Otto, and David Sickinger. 2024. Best Practices for Energy-Efficient Data Center Design. Washington, D.C.: U.S. Department of Energy Federal Energy Management Program. Walker, Willy. 2024. “The Future of Real Estate Is Digital: How Data Centers and 5G Are Shaping the Next Generation of Infrastructure.” Walker & Dunlop Market Trends, October 30. Zhang, Mary. 2023. “Types of Data Centers: Enterprise, Colocation, Hyperscale.” Dgtl Infra, November 26. ZincFive. 2024. “Data Center Energy Storage Industry Insights Report 2024.” ZONING PRACTICE OCTOBER 2025 | VOL. 42, NO. 10. Zoning Practice (ISSN 1548– 0135) is a monthly publication of the American Planning Association. Joel Albizo, fasae, cae, Chief Executive Officer; Petra Hurtado, phd, Chief Foresight and Knowledge Officer; David Morley, aicp, Editor. Subscriptions are available for $65 (individuals) and $120 (organizations). ©2025 by the American Planning Association, 200 E. Randolph St., Suite 6900, Chicago, IL 60601–6909; planning.org. All rights reserved. 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