Environmental Profile
A data-driven look at water, electricity, air quality, and pollution impact
Water & Cooling
Abundant Capacity, Modern Technology
23.3 MGD
of surplus water capacity in Rockford's system
Rockford's Water Capacity
The city has abundant surplus water capacity
Rockford's Groundwater Infrastructure
Rockford sits atop one of the most productive aquifer systems in the Midwest. The city's water system has a total capacity of 40 million gallons per day (MGD), drawn from approximately 30 municipally-operated wells spread across the region. Current municipal and industrial demand uses only about 16.7 MGD — leaving a massive surplus of over 23 MGD available.
The system draws from two primary sources: the shallow alluvial aquifer of the Rock River valley and the deeper Cambrian-Ordovician sandstone aquifer. Annual groundwater production is approximately 7.6 billion gallons per year. This isn't theoretical capacity — these are existing, permitted wells with proven output. The infrastructure is already built and paid for.
Importantly, Rockford's system doesn't draw from surface sources like the Rock River — it relies entirely on deep groundwater, which is naturally filtered and far more resilient to drought conditions than surface water supplies.
Water Usage in Perspective
A paper mill uses 5x more water than the data center at peak demand
Understanding Peak vs. Average Demand
The 3 MGD figure represents peak summer demand — the maximum water needed during the hottest months when cooling systems work hardest. Annual average consumption runs 40-50% below peak during fall, winter, and spring when outdoor temperatures are lower and less cooling is required.
3 MGD
Peak Summer
1.5-1.8 MGD
Annual Average
<0.9 MGD
With Closed-Loop
Where Does the Water Go?
Closed-loop cooling returns 90-95% of water to the system
Wastewater & Discharge Management
A critical distinction: water withdrawal is not the same as water consumption. Unlike agricultural irrigation where water is sprayed on fields and largely lost, data center cooling water is recirculated and returned to the municipal system through wastewater treatment.
With closed-loop cooling, 90-95% of withdrawn water is returned. Of the 3 MGD peak withdrawal, approximately 2.7-2.85 MGD comes back — meaning only 0.15-0.3 MGD is actually consumed.
Cooling system blowdown water (periodic discharge to manage mineral concentrations) is treated on-site using sedimentation, chemical precipitation, and pH adjustment before being discharged to municipal treatment systems. All discharge is regulated under Illinois EPA permits.
Technology Matters
Cooling technology selection is the single most important factor in determining a data center's water consumption. The choice of system can vary water use by an order of magnitude.
Evaporative Cooling
Highest water use. Water evaporates to remove heat. Consumes 3-5 MGD for a large facility. Oldest technology, still common but declining.
Closed-Loop Cooling
70% reduction in water consumption. Water circulates in a sealed system and is returned. Only 0.9 MGD consumed; 90-95% of water returns to the system.
Air-Cooled Systems
Near-zero water consumption. Heat is rejected directly to outdoor air via fans and heat exchangers. Increasingly practical in cooler climates like Northern Illinois.
Industry trend: Microsoft, Google, Oracle, and Meta have all committed to water-positive or zero-water cooling operations. Modern facilities increasingly adopt hybrid approaches combining air cooling with limited water-based systems.
Drought Preparedness
Illinois experiences periodic drought conditions (notably 2000 and 2012). Data center facilities can establish drought response protocols that scale water usage based on system-wide availability, including operational adjustments and temporary load reductions.
A natural mitigation exists: seasonal demand variation. Peak cooling demand (summer) coincides with drought stress months, but winter and spring see substantially lower cooling demand — naturally moderating year-round consumption.
Additional technologies like greywater reuse, rainwater harvesting, and wastewater recycling can further reduce net freshwater consumption by 10-30%.
Aquifer Health & Sustainability
The primary concern for Rockford's aquifer isn't supply depletion — it's protection from surface contamination. The shallow alluvial aquifer is vulnerable to contamination from surface sources, and the deeper Cambrian-Ordovician sandstone aquifer is relatively close to the bedrock surface in Winnebago County.
The Illinois State Water Survey is currently studying long-term changes in aquifer water levels. Any development agreement should include comprehensive monitoring and public reporting to ensure long-term sustainable management.
A data center actually improves contamination risk vs. agriculture: no fertilizer runoff, no pesticide application, managed stormwater systems, and zero agricultural chemicals entering the soil.
The Bottom Line
Even at peak demand, the data center would use just 7.5% of Rockford's total water capacity — and modern cooling technology can reduce actual consumption to under 1 MGD.
Electricity & the Grid
800 MW Demand, 1,200 MW Committed — With Co-Located Generation
1,200 MW
of power capacity committed by ComEd for January 2028
800 MW
Facility Capacity
24%
N. IL Demand Growth 2025-30
3%
DC Share of N. IL Load (2026)
6.5 GW
Total Queue Requests
Grid Infrastructure Advantage
The Rockford site sits adjacent to existing high-capacity ComEd transmission lines, with another major transmission line approximately 1 mile away. This means the facility can access grid power without extensive new transmission construction — a critical advantage when other data center projects face 3-5 year wait times just for interconnection approval.
ComEd serves approximately 4 million customers across Northern Illinois. Their commitment to deliver 1,200 MW of capacity by January 2028 — exceeding the facility's 800 MW demand — demonstrates both the utility's confidence in the project and the grid's ability to support it.
The "Power Campus" Model
Unlike traditional data centers that depend entirely on the grid, this project uses a co-located generation model — pairing data center operations with on-site power generation. This approach directly addresses the biggest concern about data center electricity use.
Reduces Grid Strain
On-site generation means less demand on the interconnection queue, freeing capacity for other customers and easing transmission burden.
De-Risks Timelines
Energy availability is secured concurrent with facility construction — no months-long delays from traditional interconnection queues.
Protects Ratepayers
By not relying entirely on the grid, costs aren't shifted to residential and small business customers — aligning with the POWER Act's goals.
The leadership team has deep experience in renewable energy (Enel Green Power, Orsted) and utility operations (American Electric Power, Integrys) — uniquely qualified to execute this model.
Regional Demand Growth
Northern Illinois electricity demand is projected to grow 24% between 2025 and 2030, driven by economic growth, electrification of transportation and heating, and data center expansion. Data centers currently represent about 3% of total Northern Illinois load, projected to reach 13% by 2035.
The Challenge
Data centers could account for up to 72% of total electricity demand growth in Illinois between 2025-2030. System costs could increase by up to $37 billion.
The Solution
Co-located generation models (like this project) reduce grid dependency, ease transmission burden, and prevent cost-shifting to other ratepayers.
Grid Reliability: Illinois' 2025 Resource Adequacy Study projects potential power shortfalls in ComEd territory by 2029-2030 without new generation. This underscores the importance of projects that include co-located generation rather than relying solely on the existing grid.
Legislative Landscape
Illinois is evolving its approach to data center development — moving from unlimited growth incentives toward frameworks that balance economic growth with ratepayer protection and grid reliability.
101
Illinois Data Center Investment Program
27 data centers received ~$983 million in lifetime tax breaks. Includes sales/use tax exemptions and 20% income tax credit on construction wages in underserved areas. Qualification: $250M investment over 60 months, minimum 20 high-paying jobs.
Governor Pritzker's Tax Incentive Pause
Two-year suspension of new data center tax credits effective July 1, 2026. State agencies directed to conduct comprehensive studies on grid impacts and economic effects.
Act
The POWER Act (SB4016/HB5513)
Requires data centers to finance their own generation capacity (BYONCCE), use renewable sources, disclose water use, and contribute to an Energy Affordability Fund. Gaining bipartisan support.
The co-located generation model is aligned with the POWER Act's cost-causation approach — the facility funds its own generation rather than shifting costs to other ratepayers.
Grid Impact Mitigation
On-Site Generation
Co-located solar, battery storage, and other renewable generation reduce grid draw and provide redundancy.
Demand Response
Facilities can reduce consumption during peak grid stress periods, improving overall grid reliability for everyone.
Phased Construction
Facility buildout coordinated with transmission capacity expansion ensures grid infrastructure keeps pace with demand.
Renewable Spill-Over
Commitment to procure renewable energy spurs utility-scale solar and wind projects, creating jobs and clean energy benefits for all.
Illinois Data Center Landscape
Illinois is one of North America's premier data center markets alongside Virginia and Texas, with major investments from Microsoft, CyrusOne, and CloudHQ already in place.
| Project | Location | Scale |
|---|---|---|
| Rockford Data Center | Rockford, IL | 1,100 acres / 800 MW |
| Microsoft Cherry Valley | South of Chicago | 309 acres |
| CyrusOne Aurora | Aurora, IL | Multiple buildings |
The Bottom Line
With 1,200 MW committed by ComEd, existing transmission infrastructure adjacent to the site, and a co-located generation model that protects ratepayers from cost-shifting, the electricity question has clear answers.
Air Quality
Zero Emissions During Normal Operations
0
Direct air emissions during normal computing operations
Why Zero Emissions?
Servers and computing equipment produce only heat — the transformation of electrical energy into computational processes releases thermal energy that must be dissipated, but no air pollutants of any kind. Cooling systems (whether air-based, water-based, or hybrid) are fundamentally mechanical or thermal processes that redistribute heat — they don't generate pollution.
This makes data centers fundamentally different from manufacturing, chemical processing, or other industrial operations that involve combustion, chemical reactions, or material transformation. A data center is an inherently clean operation once past the construction phase.
Backup Generator Runtime
Generators operate for testing and emergencies only
That's less than 4.2 days per year
Backup Generators: The Only Emission Source
The only emission source at a data center is backup diesel generators, which exist for life-safety and equipment protection during power outages. These generators run for less than 100 hours per year — just 1.14% of the time — primarily for mandated testing and rare emergency use.
When running, generators emit particulate matter (PM), nitrogen oxides (NOx), sulfur dioxide (SO2), and carbon dioxide (CO2). Diesel generators produce 200-600 times more NOx per unit of energy than natural gas turbines — but their extremely limited runtime means total annual emissions remain minimal.
<100 hrs
Annual generator runtime
98.86%
Of the year with zero emissions
Northern Virginia Context
Much of the concern about data center air quality stems from studies of Northern Virginia's "Data Center Alley" — a uniquely dense concentration that does not apply to Rockford.
Northern Virginia has 300+ data center facilities concentrated in a few square miles — the densest cluster on Earth. Between 2015-2023: CO emissions up 196%, NOx up 111%, PM up 139%.
The Virginia health cost study estimated ~$300 million annually and ~14,000 asthma impacts — but this reflects the cumulative impact of 300+ facilities. Per-facility cost: approximately $1M or less.
Rockford: 1 facility on 1,100 acres of industrial land, not 300+ in a few square miles. Industrial zoning with greater distance to residential populations. The comparison is fundamentally different.
Important: Diesel exhaust is classified as a toxic air contaminant by the EPA. Health impacts are determined by exposure (concentration x duration). Fewer than 100 hours of intermittent generator operation in an industrial zone with significant buffer zones produces minimal population exposure.
Construction Phase Emissions
The 2-4 year construction phase will generate temporary emissions from heavy equipment, fugitive dust, and vehicle traffic — typical for any large industrial construction project. These impacts are inherently temporary and cease entirely once the facility becomes operational.
Sources
Heavy equipment, dust from grading/excavation, delivery trucks, concrete operations
Controls
Water suppression, Tier 3/4 equipment standards, designated routes, road sweeping, sediment control
Industry Trends: Moving Beyond Diesel
The data center industry is rapidly shifting away from diesel generators entirely. Within the next decade, backup diesel generators will likely be replaced across the industry.
Microsoft Commitment
Phase out all diesel generators by 2030. Replacing with battery energy storage systems (BESS) and renewable diesel.
Replacement Technologies
- Battery energy storage (BESS) — zero emissions
- Natural gas turbines — 80% fewer NOx emissions
- Renewable diesel / HVO fuels
- Hydrogen fuel cells
The co-located generation model provides additional opportunities to reduce reliance on backup generators, integrate renewable energy sources, and implement battery storage or other emerging technologies.
Regulatory Framework
Backup generators are subject to multiple layers of regulatory oversight:
EPA Title V Operating Permits
Establish emission limits, operating conditions, and monitoring procedures for major stationary sources.
NESHAP Standards
Specific emission limits for stationary reciprocating internal combustion engines (generators), including hazardous air pollutant limits.
Illinois EPA Air Quality Permits
Maximum operating hours, fuel quality standards, emission monitoring, maintenance/inspection schedules. Often more stringent than federal minimums.
Operating Hour Restrictions
Permits limit annual generator operation to 50-100 hours for testing/maintenance. Emergency operation during grid outages is unlimited but typically brief.
The Bottom Line
A data center produces zero air emissions 98.86% of the year. The remaining 1.14% comes from backup generators that are fully regulated, rarely used, and being phased out industry-wide.
Chicago Rockford International Airport is immediately adjacent and produces far more emissions from jet fuel combustion than any data center generator testing program.
The site is zoned I-2 (General Industrial) since 2008. Data centers are among the cleanest facilities permitted — compare to chemical processing, metal fabrication, or concrete batching.
Only ~200 permanent employees commuting — far less vehicle traffic than a manufacturing plant with thousands of workers.
Pollution Profile
Among the Cleanest Industrial Facilities
What Else Could Go on This Land?
All of these are legally permitted on I-2 industrial zoned property
| Metric | Data Center | Chemical Plant | Metal Fabrication | Petroleum Refinery | Warehousing |
|---|---|---|---|---|---|
| Air Emissions | Excellent | Very Poor | Poor | Very Poor | Good |
| Water Pollution | Good | Very Poor | Poor | Very Poor | Good |
| Noise Level | Good | Poor | Very Poor | Poor | Moderate |
| Truck Traffic | Excellent | Poor | Moderate | Poor | Very Poor |
| Hazardous Waste | Excellent | Very Poor | Poor | Very Poor | Good |
| Tax Revenue | Excellent | Moderate | Moderate | Moderate | Poor |
Data centers produce no smokestacks, no chemical runoff, and no hazardous waste during normal operations. They are among the cleanest industrial operations available — producing no process waste, no chemical discharge, no direct air emissions, and no hazardous materials. Here's the full picture.
Air Pollution
Zero direct emissions during normal operations. Backup diesel generators are the only source, running less than 100 hours per year (1.14%). Fully regulated under EPA Title V and Illinois EPA. Construction phase generates temporary dust and vehicle emissions (12-24 months), controlled through standard practices.
Water Pollution
Closed-loop cooling systems minimize discharge. Cooling blowdown water contains concentrated minerals and treatment chemicals — treated on-site via sedimentation, chemical precipitation, and pH adjustment. All discharge requires NPDES permits from Illinois EPA. Zero Liquid Discharge (ZLD) systems can eliminate all wastewater entirely.
Chemical / PFAS
An honest assessment: PFAS ("forever chemicals") appear in semiconductors, some cooling fluids, and certain fire suppression systems (AFFFs). This is an industry-wide concern affecting all data centers globally — not unique to Rockford. The industry is actively transitioning to PFAS-free alternatives.
Light & Thermal
24/7 security lighting creates light pollution affecting wildlife and neighbors — highly mitigable through dark-sky compliant, downward-facing fixtures. Cooling systems discharge water 10-15°F warmer than intake — manageable through proper design including heat recovery.
Stormwater Runoff
Converting 1,100 acres from agricultural land to buildings and pavement increases impervious surface, altering stormwater patterns. Illinois law and local ordinances require comprehensive stormwater management plans including retention/detention ponds that store runoff, allow sediment settlement, and release water gradually. Construction erosion is controlled through erosion blankets, silt fences, and temporary sediment basins. An NPDES Construction General Permit from Illinois EPA is required.
PFAS: An Honest Look
Per- and polyfluoroalkyl substances ("forever chemicals") are an emerging and legitimate environmental concern that warrants transparent discussion.
Where PFAS Appears in Data Centers:
Semiconductors: Server chips manufactured using processes that may incorporate PFAS as surfactants and processing aids. Exact compounds largely proprietary.
Cooling Systems: Fluorinated refrigerants may contain PFAS-related compounds. Ethylene glycol in cooling loops can contain trace contamination.
Fire Suppression: Aqueous film-forming foams (AFFFs) are known PFAS sources. Industry has largely moved away, but some facilities still use them.
Health Risks:
PFAS are extraordinarily persistent due to strong carbon-fluorine bonds. They don't degrade through natural processes and bioaccumulate in tissues. Linked to cancer, liver damage, reproductive effects, immune system suppression, and thyroid disease.
Industry Response:
The EPA is prioritizing review of PFAS in data center operations. Regulatory agencies are developing standards for PFAS in drinking water and environmental discharge. The industry is actively developing PFAS-free alternatives, though the transition is gradual due to performance requirements.
Key point: This is an industry-wide issue affecting all data centers and electronics manufacturers globally — not unique to the Rockford facility. Proactive management (disclosure, monitoring, transition to alternatives) would position this facility as a leader in addressing the concern.
Recommended Development Conditions
To ensure maximum environmental protection, any development agreement should include these conditions:
- 1
Full PFAS disclosure — all PFAS-containing products used on site, including cooling fluids, fire suppression agents, coatings, and sealants.
- 2
PFAS-free alternatives where commercially available, with a timeline for transitioning remaining products.
- 3
Baseline environmental monitoring of groundwater and surface water quality before construction, establishing a clear pre-development benchmark.
- 4
Ongoing periodic monitoring with public reporting, so that any changes can be detected early and addressed transparently.
- 5
Zero Liquid Discharge (ZLD) or near-ZLD cooling design to prevent process wastewater from entering the municipal system or local waterways.
- 6
Stormwater management meeting or exceeding state and local standards, with retention/detention systems.
- 7
Dark-sky compliant lighting to minimize light pollution impacts on wildlife and neighbors.
Compared to Current & Alternative Uses
The land is currently used for agriculture, which contributes its own pollution: fertilizer runoff (nitrogen and phosphorus causing eutrophication), pesticide and herbicide application, soil erosion from tilling, and machinery exhaust. Agricultural runoff is a major contributor to water quality degradation.
Alternative I-2 uses — manufacturing, chemical processing, automotive assembly — typically produce far greater pollution: substantial air emissions, large wastewater volumes, hazardous waste generation, and toxic material storage.
Bottom line: Compared to what else could legally occupy this industrially-zoned land, a data center represents one of the least polluting industrial uses available.
Multi-Layered Regulatory Framework
Data centers are subject to comprehensive environmental regulation ensuring pollution controls are applied, monitored, and enforced:
Clean Air Act
Emissions control from stationary sources including backup generators. National Ambient Air Quality Standards ensure protection.
Clean Water Act
NPDES permits for all pollutant discharge. Limits on temperature, pH, dissolved solids, and nutrients.
RCRA (Hazardous Waste)
Regulates hazardous waste generation, storage, and disposal. Data centers generate minimal hazardous waste (battery acid, spent oils).
Illinois EPA & Pollution Control Board
State-specific standards for water quality, air quality, and hazardous waste. Often more stringent than federal minimums.
Stormwater Management Ordinances
City and county regulations for retention/detention systems, construction erosion control, and post-construction management.
Industry Best Practices
Leading data center operators exceed minimum regulatory requirements. Implementing these practices would position the Rockford facility as environmentally responsible:
Zero Liquid Discharge
Recycle nearly all process water, requiring only periodic concentrated brine discharge.
PFAS-Free Commitment
Use PFAS-free refrigerants, cooling fluids, and fire suppression where commercially available.
Green Chemistry
Less toxic, biodegradable alternatives for cooling system chemicals, corrosion inhibitors, and biocides.
Sustainability Reporting
Public reporting of water consumption, discharge quality, energy efficiency, and emissions data.
The Bottom Line
Data centers are among the cleanest industrial operations available — no process waste, no chemical discharge, no direct air emissions. With proper development conditions and multi-layered regulatory oversight, environmental impacts can be effectively managed.
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