Data Centers: Comments and Recommendations

September 27, 2026

 

Introductory Comments

Cape Fear River Watch (CFRW) is a local environmental advocacy organization focused on the health of the Cape Fear River watershed. Data Centers are a new and evolving threat to the waters of the Cape Fear River Basin. Given our focus and responsibility, we currently oppose the construction of data centers until the threats to local water supplies, and broader environmental impacts, are fully vetted. CFRW will continuously review our position on data centers as their best management practices, alternatives, and impacts continue to evolve.

Several counties in North Carolina have paused accepting new data center projects. If data centers are to be built within the Cape Fear River watershed, we ask local authorities to adopt rules and criteria to significantly lessen the impact. We demand full transparency with the public and local stakeholders regarding the plan, especially on environmental and health impacts. Non-Disclosure Agreements are inappropriate given the far-reaching impacts of data centers on the community. 

This position statement is divided into two parts including: 1) A summary of environmental impacts and recommendations, particularly related to water use and water quality, and 2) A more detailed description of the many issues and concerns related to data centers in general.

 

Summary: Environmental Impacts and Recommendations

 

Water Use: Data centers require large amounts of water for cooling and for steam generation for electricity. For cooling, small to medium data centers may use up to 0.5 million gallons per day and large data centers can use up to 5 million gallons per day. In addition, electricity generation to operate the data centers requires large volumes of thermoelectric water for cooling and steam generation. Public and private surface and groundwater resources should not be jeopardized including in high demand warmer months. And sourcing this large amount from groundwater risks a cone of depression that may reach far beyond property boundaries, depleting this source for surrounding public and private wells.

Recommended Guidelines:

  • Utilize the best water conservation practices, e.g. water-efficient cooling systems: Closed-loop cooling, immersion cooling, and/or using non-potable water.
  • Do not utilize air cooling and evaporative cooling, as they are inefficient and use too much water, respectively.
  • Oppose immersion cooling fluids using fluorocarbons.
  • Provide the projected true water demands including the source, daily use, and peak demand.
  • Minimize surface water withdrawals and oppose larger groundwater withdrawals that might lead to groundwater depletion and even a cone of depression. 
  • Assess the cumulative impacts of water withdrawals in addition to existing water withdrawals. Knowledge of the total withdrawals, from all uses, is critical for monitoring and managing our water supplies in the watershed. 

 

Water Discharges: Cooling water discharges will likely be above normal temperature for receiving waters, causing “thermal pollution”, which adversely affects wildlife, raises biological oxygen demand, reduces dissolved oxygen and encourages toxic algae blooms; these are already concerns in the Cape Fear River. Cooling water often contains additives that could be toxic to the ecosystem or human consumption. Due to their extremely large footprint, with mostly impervious surfaces, data centers create large volumes of stormwater runoff. 

Recommended Guidelines:

  • Cooling water should not be discharged directly into the river or streams without being cooled to ambient temperature. 
  • Cooling water must be assessed for any harmful chemicals, especially fluorocarbons or other PFAS compounds, to ensure the wastewater treatment systems can effectively remove them before being discharged.
  • Oppose new NPDES-permitted wastewater discharges by data centers into the Cape Fear River or its tributaries. The data centers should be required to provide wastewater treatment technology that removes any pollutants that cannot be removed by municipal or other waste treatment plants.
  • Require non-discharge stormwater control measures to prevent runoff into surrounding waters such as specifically designed treatment wetlands or infiltration basins.

 

Additional Environment and Community Impact Concerns:

Data centers use extremely large amounts of electrical power, up to 500MW (equivalent to 400,000-500,000 homes), which has sometimes increased the electricity rates for local consumers. The reason is that high demand strains the existing power generation infrastructure (power plant need, grid connections, substations, etc.) leading to potential increases to ratepayers. 

Much of the electricity used by data centers is generated from fossil fuels with resulting impacts on climate change, air quality, and water use for steam generation and cooling. Proposals for use of nuclear plants, such as small modular reactors, also use water for steam generation and cooling. Power generation and operation create noise pollution, too

Recommendations:

  • Energy demand, both current and future, must be clearly stated with the expected sources of energy generation documented. Renewable sources are preferred and should be incentivized for their low water use, noise, and air pollution. Rate hike increases caused by the data center should be borne by the centers.
  • Minimize the use of diesel generators and gas turbines.
  • Minimize noise pollution; baseline readings prior to construction measured on site and at the perimeter of the property should be the goal for the centers.
  • Assess pre-construction air quality and model the expected data center impacts including backup generator output.

 

Supporting Data for Cape Fear River Watch Recommendations

Detailed Description of the Issues and Concerns Related to Data Centers

 

Introductory Comments

Cape Fear River Watch is an environmental advocacy organization focused on the health of the Cape Fear River Basin. A new and potentially expanding threat to the waters of the Cape Fear River watershed is Data Center construction and operations. The many uncertainties with water sourcing, impacts on local water supplies, and total potential cumulative impact on the watershed, lead Cape Fear River Watch to oppose further construction until these and other impacts to local communities and the watershed are fully vetted. A temporary moratorium, such as is currently in place in 11 counties and 17 municipalities in North Carolina is an appropriate course of action. 

If data center construction is considered in the Cape Fear watershed, we ask that the operators/facilities and local authorities adopt rules that lessen any negative impacts to our waters as well as to other issues that have occurred with data center construction including increased energy use and rate hike increases, noise, stormwater and reduced air quality, and loss of significant agricultural and/or natural areas that are important to the community. We encourage local authorities of counties and municipalities to adopt meaningful limits on data center expansion to ensure community and watershed health.

 

Cape Fear River Watch Position

As stated above, Cape Fear River Watch advocates for thoughtful, transparent, and slower paced planning if data centers are considered for construction in the Cape Fear watershed. Without this approach, we suggest that a pause/moratorium be put in place until the following are guaranteed:

  1. Require that data centers utilize the best water conservation practices, e.g. water-efficient cooling systems. Closed-loop cooling, immersion cooling, and/or using non-potable water are recommended instead of air cooling and evaporative cooling, which are inefficient and use too much water, respectively. 
  2. Data center developers must provide their projected water demand for the project including source(s), daily use, peak demand, and plans for wastewater disposal. There should be no impact on the availability or quality of the community’s surface and groundwater resources. The best approach and one that CFRW recommends is that a comprehensive water management plan includes all water withdrawals in the watershed in order to plan for source needs, drought, and ecological flow minimums.
  3. Current and future energy demand must be clearly stated, and there should be requirements for energy efficiency. Where possible, local sources of renewable energy should be used as this provides cleaner energy with much less water. The goal should be to minimize diesel generators and loud/large gas turbines. Rate hikes, if related to increased energy demand from the data centers, should be borne by the data center.
  4. We ask that local governments provide transparency in discussions with data centers and provide that information to the public. Environmental impacts and health impacts should be clearly stated. There should be no NDAs allowed. 
  5. Other issues such as noise and stormwater management should be addressed up front and communicated to the public before approvals. And as there is now a push to move data centers into more rural areas to avoid urban conflicts, loss of valuable agricultural lands and wetlands is an important consideration.

A review of the Issues and Potential Issues of Data Center water use is provided below.

 

Potential Issues and Impacts

It has been said that data centers will benefit communities by providing new jobs and boosting the local economy as they will create new jobs, tax revenue, and many associated business opportunities. These claims have been refuted across the country with estimates that communities are gaining less than half of the promised jobs. Regardless, the environmental and neighborhood concerns for quality of life are equally important. (3) Below we highlight several of the concerns that we have as well as those that have been voiced in many parts of NC and across the country.

There are now 4,767 data centers in the United States. Virginia ranks #1 (685) followed by Texas (466) and California (331). NC is 13th in the country with 115 (91 operational, 4 under construction, 18 planned, 2 paused) and most of these are in Mecklenburg, Wake, and Durham counties. The total energy demand of the centers in NC is 5.1 GW; this is equal to the production of medium-size coal or natural gas plants or a little less than 1/3 of the output from the Southport nuclear plant. Most of the currently operating centers are in more urban areas (87%) but most of the planned ones are proposed for more rural areas (67%).

 

Water Issues

Source of the Water Issues

CFRW’s mission focuses on protecting water resources in the Cape Fear River watershed. Data centers use extremely large volumes of water. Recent droughts have highlighted the importance of planning water shortages when considering future data centers.

Water is consumed during the cooling of computer servers and processors as well as the air inside the facility. Water cooling is much more efficient than air, but water use may be quite high, as indicated in an environmental and energy study in 2025 stated a large data center could use 5 mgd or 1.8 bg/yr and a medium-size center could consume >300,000 gpd or 110 mg/yr. A large data center will exceed 10,000 ft2, contain 10s of thousands of servers and use 10 to >100 MW of power while a medium center is up to 10,000 ft2, houses hundreds to a few thousand servers, and consumes 1 to 100 MW of power. Newer data centers are often even larger; one planned in Statesville, NC will use 500 MW and one in Greensboro, NC will demand 300 MW. For comparison, an average size coal or natural gas electricity generating plant produces 600 MW. Energy demand is critical, but generation also requires large amounts of water for thermoelectric cooling, Nuclear and coal use the most water followed by natural gas. Renewable energy requires much less water.

There are multiple methodologies employed for cooling data centers. Most of the older data centers, though some are still planned with this technology, use air-cooling or evaporative cooling. Newer methods are less water intensive including closed-loop cooling and immersion cooling etc. Immersion cooling methods, especially the two-phase methods, use fluorinated liquids which degrade into the PFAS compound trifluoroacetic acid (TFA). These are likely to leak into the atmosphere and may be disposed of through wastewater discharges. 

Comments on specific sources of water are given below.

 

Groundwater:

  • Groundwater is important for irrigation and for public and private water sources with well over 2 million people in NC using groundwater for their potable water supply
  • Overuse of groundwater may lead to lowered water tables and a cone of depression that may extend beyond the property boundary, impacting private wells.
  • Cones of depression that have formed from overuse include CFPUA wells in the Castle Hayne aquifer and even more so with groundwater withdrawal early in the development of the Tar Heel Processing Plant. Withdrawal of 1 – 3 mgd there led to a cone of depression in the Black Creek and Cape Fear aquifers. The State required reduction in groundwater withdrawal, and this led to a change to withdrawal from the Cape Fear River.
  • Groundwater depletion may be even more problematic in the Piedmont hard rock country. Groundwater use should have minimal to no use in data centers.

 

Surface Water:

  • Surface water supplies in the Cape Fear Basin provide water for over 2 million people and over 500,000 in the Lower Cape Fear. The Cape Fear River includes all or parts of 29 counties and 114 municipalitie.
  • Although Cape Fear River water flow is generally adequate to meet demand, growing populations and water demand from industry require planning. And in the face of drought and interbasin transfers, planning is even more important. The current statewide drought and the Fuquay Varina Interbasin Transfer requesting over 6 mgd be transferred from the Cape Fear to the Neuse watershed are cumulative. These are even more important during warm periods.
  • Withdrawals without adequately assessing cumulative impacts should not be allowed.

 

Wastewater and Stormwater:

Wastewater from cooling discharges and stormwater from the large built upon areas risk harm to the Cape Fear and its tributaries. What are the issues?

  • Cooling water discharges will likely have above normal ambient temperature, which is termed thermal pollution. This water discharge may adversely affect wildlife, raise biological oxygen demand, reduce dissolved oxygen, and encourage toxic algae blooms, which is already a concern for the Cape Fear River.
  • Wastewater during construction and operational phases should be treated on site.
  • The large impervious footprint of data centers will lead to large volumes of stormwater runoff. Stormwater control measures must be put in place to ensure that there is no runoff into surrounding waters.