WATER WITHDRAWAL VOLUME
CyrusOne Yorkville — water cap reduction
Kendall County / Yorkville
Yorkville negotiated a dramatic reduction in CyrusOne's permitted water draw — from 500,000 gpd to 40,000 gpd — with penalties above 1.7× the average daily allotment.
Key data: **500,000 gpd reduced to 40,000 gpd maximum**; penalties above 1.7× average daily allotment; 228-acre site
VERIFIED PRIMARYLimitation: Reduction reflects a shift to closed-loop/air cooling; earlier reporting cited 393 gal/acre/day for CyrusOne.
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WATER WITHDRAWAL VOLUME
Project Cardinal — water demand
Kendall County / Yorkville
Cardinal's projected buildout demand rose during review, and the overall campus operates under an average-day cap plus a Lake Michigan connection fee.
Key data: Cardinal 350,000 gpd at buildout (increased from 310,000); campus cap 42,000 gpd average plus Lake Michigan connection fee
CORROBORATEDLimitation: The 350,000 gpd buildout figure and the 42,000 gpd campus average appear inconsistent in scope (peak buildout vs. contractual average); reconcile against the annexation agreements at [Project Cardinal](https://www.yorkville.il.us/906/Project-Cardinal-Data-Center-Campus-Anne) and [Project Steel](https://www.yorkville.il.us/905/Project-Steel-Data-Center-Campus-Annex-A).
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WATER WITHDRAWAL VOLUME
CyrusOne Sangamon County
Sangamon County
CyrusOne states the Sangamon campus uses closed-loop cooling with minimal ongoing water demand.
Key data: ~1,100 gallons/day per building, closed loop
DISCOVERY LEADLimitation: Developer-published figure with no permit or agreement cap found to enforce it.
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UTILITY INTERCONNECTION QUEUE
Yorkville Data Center Impact Analysis (The Power Bureau)
Kendall County / Yorkville
A city-commissioned analysis is the best interconnection documentation found in any of the three states. It reports that PJM and ComEd engineering analyses concluded the campus can connect without reducing reliability after developer-funded upgrades, that the interconnection is electrically isolated from ComEd's local network, and that the load is already in PJM's load forecast.
Key data: Target **960 MW** growing from 2027 operations; service via modification of ComEd's **Plano substation** plus extension of **two 345 kV lines**; developer-owned, developer-paid substation; load already included in PJM's load forecast; interconnection approvals already obtained
VERIFIED PRIMARYLimitation: Commissioned by the city and reliant on developer, ComEd, PJM, and FERC materials plus proprietary software; it reports conclusions but does not reproduce the underlying study numbers, queue positions, or upgrade cost allocations. Contains **no** environmental, EJ, air, or cumulative-impact analysis.
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UTILITY INTERCONNECTION QUEUE
PJM queue activity near Yorkville
Kendall County
Public PJM queue records near the Yorkville site are largely solar/battery or withdrawn gas, not the data center load itself — consistent with the load being served through transmission upgrades rather than a new generator queue position.
Key data: AH2-258 (solar/battery); Plano 345 kV V1-022, 380 MW; AF1-200, 2,100 MW, withdrawn/moved to TC1
DISCOVERY LEADLimitation: Aggregator data; see also [Plano V1-022](https://interxdata.com/projects/plano-345kv-pjm-queue-v1-022/) and [AF1-200](https://interxdata.com/projects/plano-345-kv-pjm-queue-af1-200-moved-to-tc1/). Not verified against PJM's official queue.
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UTILITY INTERCONNECTION QUEUE
PJM co-location / behind-the-meter rules and load growth
PJM footprint (incl. northern IL)
PJM has proposed a materiality threshold for co-located load and projects very large data-center-driven demand growth, which frames the queue environment for all Illinois anchors.
Key data: Proposed **50 MW** materiality threshold for co-located/BTMG service; PJM data center load growth of roughly **+30 GW 2025–2030**
CORROBORATEDLimitation: Load growth figure from [PJM Inside Lines 2025 year in review](https://insidelines.pjm.com/2025-year-in-review-planning-prepares-for-burgeoning-electricity-demand/). Regional, not project-specific.
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COMMUNITY OPPOSITION OR LITIGATION
CyrusOne Sangamon County — litigation
Sangamon County
Residents of Waverly and Virden filed a five-count declaratory-judgment suit after the county board approved zoning 17-10. The suit's most concrete allegation is that **CyrusOne's own noise model exceeded the county's 50 dBA property-line standard**, and it cites the company's on-record acknowledgement of an unresolved noise problem at its Aurora campus.
Key data: Filed 2026-07-06, **five counts**; defendants Sangamon County Board, Sangamon County, and C1 Sangamon LLC (Delaware LLC, principal address = CyrusOne HQ); some plaintiffs live 3/4 mile from the site; noise standard **50 dBA at property line** exceeded by developer's own model
VERIFIED PRIMARYLimitation: Case number not stated; no court date listed on the circuit clerk's website as of publication. Plaintiff names not published.
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COMMUNITY OPPOSITION OR LITIGATION
CyrusOne Sangamon County — approval process
Sangamon County
The county board tabled the vote in March after a 3.5-hour meeting, then approved 17-10 in April; the ZBA had recommended approval 5-0.
Key data: ZBA 5-0; County Board **17-10** approval 2026-04-07 after 2026-03-23 tabling; ~$500M project
CORROBORATEDLimitation: Corroborated by [Sangamon Reporter](https://www.sangamonreporter.com/post/county-board-approves-data-center-zoning) and [NPR Illinois](https://www.nprillinois.org/sangamon-county/2026-03-23/the-sangamon-county-board-tables-a-vote-on-a-massive-data-center).
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COMMUNITY OPPOSITION OR LITIGATION
Joliet Technology Center — litigation
Will County / Joliet
Three unincorporated Elwood residents organized as Joliet Residents For Responsible Growth sued to void the council's approval, alleging unconstitutional rezoning of agricultural land, defective public notice, an Open Meetings Act violation, denial of cross-examination, and — most notably — that the city's planning director is the daughter of a person with a financial stake in the project.
Key data: Filed 2026-05-18, Will County Courthouse; plaintiffs Craig Doorneweerd, Rhonda Doorneweerd, Pedro Garcia; defendants City of Joliet, Powerhouse Hillwood Holding, HW Technology Park Development, American Real Estate Partners; challenges a **$20B, 795-acre, 24-building, 6,936,000 sq ft, 1.8 GW** campus; hearing set for Sept 8
VERIFIED PRIMARYLimitation: Case number not stated. The conflict-of-interest allegation names Planning Director Jayne Bernhard; it is an unadjudicated allegation.
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COMMUNITY OPPOSITION OR LITIGATION
Joliet Technology Center — approval votes
Will County / Joliet
The council approved 8-1 after a hearing exceeding six hours; the plan commission had advanced it 7-1.
Key data: Plan Commission 7-1 (2026-03-05); City Council **8-1** (2026-03-19/20) after a 6+ hour hearing
CORROBORATEDLimitation: Also [The Real Deal](https://therealdeal.com/chicago/2026/03/16/joliet-panel-advances-massive-data-center/).
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COMMUNITY OPPOSITION OR LITIGATION
Project Cardinal — litigation and settlement
Kendall County / Yorkville
Residents incorporated as Preserve Our Yorkville & Community LLC and sued the city and Pioneer Development; the case reached a conditional settlement that rephased the project — one of the few negotiated resolutions found.
Key data: Suit filed 2026-04-29 against the city and Pioneer over a 1,034-acre approval; conditional settlement rephasing the project approved 2026-06-30
CORROBORATEDLimitation: Filing detail from [Shaw Local](https://www.shawlocal.com/kendall-county-now/2026/04/29/yorkville-residents-file-lawsuit-against-the-city-to-halt-the-1034-acre-project-cardinal-data-center/). Case number and settlement terms not retrieved.
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COMMUNITY OPPOSITION OR LITIGATION
EGV data center cluster — opposition
Cook County / Elk Grove Village
The mayor defended the village's data center concentration at a packed public hearing; the village is described in coverage as the "data center capital of the Midwest" as Gov. Pritzker calls for statewide regulation.
Key data: Packed public hearing 2026-05-21
CORROBORATEDLimitation: No litigation found against EGV approvals; see also [NBC Chicago](https://www.nbcchicago.com/news/local/data-center-capital-of-the-midwest-expands-as-pritzker-calls-for-regulations/3952720/).
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COMMUNITY OPPOSITION OR LITIGATION
Grayslake data center (not an anchor project)
Lake County / Grayslake
Litigation over data center approvals extended to a fourth Illinois community in August 2026, indicating a spreading pattern rather than isolated disputes.
Key data: Lawsuit filed August 2026
DISCOVERY LEADLimitation: Outside the anchor project list; included as pattern evidence. Details not extracted.
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RATEPAYER OR GRID IMPACT
ICC large-load deposit requirements
ComEd territory (statewide)
The Illinois Commerce Commission approved ComEd's plan to increase deposits required from large-load customers such as data centers, described by regulators as a first step toward protecting other ratepayers.
Key data: ICC approval 2026-03-19/20; characterized as "an important first step"
CORROBORATEDLimitation: Deposit dollar amounts and thresholds not captured; ICC docket number for this specific decision not obtained.
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RATEPAYER OR GRID IMPACT
ComEd rate reconciliation citing data center integration
ComEd territory (statewide)
ComEd filed a large rate reconciliation explicitly citing 2025 data center integration costs — the clearest dollar-denominated ratepayer link found in Illinois.
Key data: **$234.3M** reconciliation filed 2026-05-01
CORROBORATEDLimitation: The share of the $234.3M attributable specifically to data centers was not broken out in the fetched coverage. Related grid plan docket: [ICC P2023-0055](https://www.icc.illinois.gov/docket/P2023-0055/documents/353641/files/619131.pdf).
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RATEPAYER OR GRID IMPACT
CyrusOne Sangamon County — rate claims
Sangamon County
The county's official FAQ states the project will use Ameren's existing grid with no resulting bill increase for other customers — a claim the litigation disputes for lack of utility documentation.
Key data: No bill increase claimed; existing Ameren grid; lawsuit alleges the petition lacked "adequate documentation" from utilities
VERIFIED PRIMARYLimitation: Government-published developer claim; no interconnection study or utility letter was located to substantiate it.
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AGRICULTURAL OR LAND USE CONVERSION
Joliet Technology Center — farmland conversion
Will County / Joliet
The approval record acknowledges the land "has been farmland throughout its history" while noting the 2007 South Side Comprehensive Plan designated it industrial; the lawsuit's core constitutional claim is that agricultural-to-light-industrial rezoning bears no substantial relation to public welfare.
Key data: ~795 acres of historic farmland rezoned agricultural → light industrial; industrial designation dates to the 2007 South Side Comprehensive Plan
VERIFIED PRIMARYLimitation: No acreage-of-prime-farmland classification (LESA score) was found.
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AGRICULTURAL OR LAND USE CONVERSION
CyrusOne Sangamon County — AIMA
Sangamon County
An Agricultural Impact Mitigation Agreement with the Illinois Department of Agriculture was confirmed for the project — the only state-level farmland mitigation instrument found across the three states — but its terms are not published.
Key data: AIMA with Illinois Dept. of Agriculture confirmed; terms not published
CORROBORATEDLimitation: Existence reported via [Sangamon County project page](https://sangamonil.gov/departments/a-c/county-board/proposed-cyrusone-data-center) and [CyrusOne FAQ](https://www.cyrusone.com/sangamon-county-community-faq); the executed document was not located. For reference, the department's [standard solar AIMA template (PDF)](https://agr.illinois.gov/content/dam/soi/en/web/agr/resources/aima/documents/std-solar-aima.pdf) shows typical drainage/topsoil/restoration terms.
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AGRICULTURAL OR LAND USE CONVERSION
Project Cardinal / Steel / CyrusOne campus
Kendall County / Yorkville
Yorkville annexed and rezoned over a thousand acres of farmland in a single campus approval after a roughly six-hour meeting.
Key data: 1,034–1,037 acres approved; 228 acres for the CyrusOne portion
CORROBORATEDLimitation: Acreage varies slightly by source (1,034 vs. 1,037); no AIMA found for the Yorkville projects.
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DECOMMISSIONING PROVISION
Decommissioning bonds / removal assurance
statewide (Joliet, Yorkville, Sangamon)
**NOT_FOUND.** No decommissioning bond, removal escrow, site-restoration requirement, or end-of-life provision was found in the Joliet approval full text, the Yorkville annexation agreements and negotiated conditions, or the Sangamon County zoning record. Illinois's negotiated agreements concentrate almost entirely on up-front payments, water caps, and noise — not end-of-life.
Key data: No decommissioning provision located in any Illinois anchor approval
VERIFIED PRIMARYLimitation: Searched the Joliet full-text ordinance, Yorkville annexation agreement pages ([Cardinal](https://www.yorkville.il.us/906/Project-Cardinal-Data-Center-Campus-Anne), [Steel](https://www.yorkville.il.us/905/Project-Steel-Data-Center-Campus-Annex-A), [CyrusOne Phase 2](https://www.yorkville.il.us/923/C1-Yorkville---Phase-2-Data-Center-Campu)), and [Sangamon Title 17 zoning code (PDF)](https://energyzoning.org/sites/default/files/PDF/17167_Sangamon%20_20220927.pdf). Absence is the finding; full executed annexation agreements (as opposed to their web summaries) were not all obtained.
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FISCAL IMPACT LOCAL GOVERNMENT
Joliet Technology Center — fiscal package
Will County / Joliet
Joliet secured what appears to be the largest community benefit package of any project in the three states — with **no city incentives or abatements granted** — including a $20M payment within 30 days of closing.
Key data: ~**$310M** property taxes over 30 years + ~**$40M** utility taxes; **$100M community benefit** with **$20M within 30 days of closing** and proportional payments per phase; **no city incentives or abatements**; mayor cited $677M in property taxes for Joliet Township HS
VERIFIED PRIMARYLimitation: The $677M schools figure is a mayoral statement from [the city's announcement](https://www.joliet.gov/Home/Components/News/News/5640/41), not an independent projection; the $310M/$40M figures are projections over 30 years, undiscounted.
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FISCAL IMPACT LOCAL GOVERNMENT
Yorkville campus — up-front payments
Kendall County / Yorkville
Yorkville extracted large up-front payments due at first building permit from all three campus developers, front-loading fiscal benefit rather than relying on future tax streams.
Key data: **Project Cardinal $51M, Project Steel $40M, CyrusOne $15M** up front at first building permit
VERIFIED PRIMARYLimitation: Whether these are impact fees, prepaid taxes, or unrestricted contributions was not clarified in fetched coverage.
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FISCAL IMPACT LOCAL GOVERNMENT
CyrusOne Sangamon County — tax impact
Sangamon County
The project projects meaningful recurring property tax revenue with no abatement requested, naming the specific taxing bodies that benefit.
Key data: ~**$6M/year** property tax at full buildout; **no abatement requested**; beneficiaries include North Mac schools, fire and library districts
DISCOVERY LEADLimitation: Developer projection; not verified against a county assessor estimate.
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NOISE OR TRAFFIC IMPACT
CyrusOne Sangamon County — noise
Sangamon County
This is the sharpest noise finding across all three states: the county's 50 dBA property-line standard versus the developer's own model showing exceedance, plus documented "unbelievable noise" complaints from residents near CyrusOne's existing Aurora campus.
Key data: **50 dBA at property line**; CyrusOne's own model several dB above the cap; on-record acknowledgement of an unresolved noise problem at Aurora
VERIFIED PRIMARYLimitation: The exact modeled dBA value was not reported; "several decibels above" is the paper's characterization of the filing.
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NOISE OR TRAFFIC IMPACT
Joliet Technology Center — noise and traffic
Will County / Joliet
The applicant claims property-line noise at or below 65 dB against Illinois Pollution Control Board octave-band limits; the lawsuit alleges the traffic study ignored the multi-year construction window entirely.
Key data: IPCB limits 40–75 dB by octave band; model ordinances 60–70 dB; applicant claims ≤65 dB at property line; lawsuit alleges the traffic study omitted the **5–7 year construction window**
VERIFIED PRIMARYLimitation: City staff's position was that noise would be "mitigated by the structures themselves, as well as by the landscape berms" — no measured or modeled dBA figures were published.
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NOISE OR TRAFFIC IMPACT
Yorkville campus — monitoring conditions
Kendall County / Yorkville
Yorkville imposed continuous noise monitoring devices and construction traffic monitoring plus a hard deadline for roadway improvements — the most operationalized noise/traffic conditions found in Illinois.
Key data: Continuous noise monitoring devices required; construction traffic monitoring; roadway improvements required by **2027-11-30**
VERIFIED PRIMARYLimitation: No dBA limit was reported alongside the monitoring requirement; enforcement mechanism unclear.
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CUMULATIVE REGIONAL IMPACT
EdgeConneX EGV — cumulative NAAQS analysis
Cook County / Elk Grove Village
Illinois EPA's Modeling Unit performed and audited an actual **cumulative** NAAQS analysis for annual NOx, incorporating nearby inventory sources and monitored background. This is the only genuine quantitative cumulative air analysis found in any of the three states.
Key data: Annual NO2: modeled 41.68 + background 32.34 = **74.02 µg/m³** (applicant) vs. 41.71 + 35.42 = **77.12 µg/m³** (agency audit), against a NAAQS of **100 µg/m³**; background monitor Schiller Park AQS 17-031-3103 (~7 km), annual NO2 design values 17.21 / 17.01 / 18.82 ppb for 2022/2023/2024; annual NO2 impact 2.18 µg/m³ exceeded the 1 µg/m³ SIL, triggering the cumulative analysis
VERIFIED PRIMARYLimitation: Cumulative treatment covers annual NOx only; secondary PM2.5/ozone were assessed using a hypothetical source in Stephenson County ~145 km away, a MERPs screening approach rather than site-specific modeling. Cumulative analysis did not identify a NAAQS exceedance.
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CUMULATIVE REGIONAL IMPACT
Prime Data Centers — cumulative concern, qualitative
Cook County / Elk Grove Village
Illinois EPA acknowledged in writing that Elk Grove Village hosts concentrated manufacturing, freight logistics, and "several data centers," and that PM2.5 and HAP increases "may present concerns, particularly where other industrial sources are located nearby" — then produced **no quantitative multi-source analysis**. Modeling showed the project alone exceeded 24-hour PM2.5, 24-hour PM10, and 1-hour NO2 significant impact levels before controls.
Key data: 24-hr PM2.5, 24-hr PM10, and 1-hr NO2 each **exceeded the applicable SIL before additional controls**; Modeling Unit recommended diesel particulate filters on **20 of 39** emergency generators
VERIFIED PRIMARYLimitation: The agency explicitly states no combined modeled concentrations from Prime Data plus other nearby sources were produced — the cumulative concern was identified but not quantified.
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CUMULATIVE REGIONAL IMPACT
EGV data center concentration
Cook County / Elk Grove Village
Elk Grove Village hosts around twenty data centers occupying roughly 4.5 million square feet inside a 66-million-square-foot business park — the densest cluster identified in Illinois.
Key data: ~**20 data centers, ~4.5M sq ft** within a 66M sq ft business park
CORROBORATEDLimitation: Also covered by [Daily Herald](https://www.dailyherald.com/20260407/technology/power-water-and-worry-how-growing-data-center-concerns-are-being-addressed-locally-and-statewide/). Journalistic count.
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CUMULATIVE REGIONAL IMPACT
State-level cumulative impact assessment
statewide
**NOT_FOUND.** No Illinois agency has produced a cumulative regional assessment of data center water, power, or air impacts. The closest available analysis is a national NGO report on data center water stress.
Key data: No state cumulative assessment located
DISCOVERY LEADLimitation: Searched Illinois EPA, ICC, and Illinois Dept. of Agriculture. Illinois EPA's cumulative work is permit-by-permit air modeling only (see EdgeConneX row above), with no water or regional load equivalent.
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