Data centers

    Data Center Feasibility Study: Colocation, Enterprise, Edge and Hyperscale Shells

    By Sarrah Allen, MAI, Principal · Updated

    A data center feasibility study tells a lender whether one specific data center can get the power it needs, on the terms the utility will offer, and lease or operate well enough to pay its debt at the coverage the capital source requires. The building matters less than it does for most property types. The power contract, the tariff, the tenant and the timing carry the file.

    Four facts frame almost every data center loan request in late 2026:

    • Construction has never moved this fast. Private data center construction ran at a seasonally adjusted annual rate of $96,462 million in September 2026 (preliminary), up from $50,700 million a year earlier and $1,922 million in September 2014, the first September Census reports [1].
    • Electricity use has roughly tripled in a decade. Data centers used 58 TWh in 2014 and 176 TWh in 2023, about 4.4% of U.S. electricity, and a federal laboratory estimate puts 2028 between 325 and 580 TWh [8][9].
    • Utilities now write rules for large loads. Georgia, Kansas, Missouri and Pennsylvania regulators have approved large-load terms with longer contracts, minimum bills, collateral or study deadlines since January 2025 [18][19][21][22].
    • Federal grid rules are in motion. The Federal Energy Regulatory Commission opened a co-location investigation of the largest regional grid operator in February 2025 and has a large-load interconnection docket open since October 2025 [12][15].

    This page sets out what the study must prove for each kind of data center, how each capital source reads the file, and where the public data a lender will recognize can be found. It covers colocation (retail and wholesale), enterprise facilities, edge sites and powered or hyperscale shells. It also includes a 50-state panel built from Census and Energy Information Administration data (Exhibit 21) and a calculator that turns critical IT load, power usage effectiveness and the power price into an energy cost and a coverage ratio.

    Every study ends in one of three conclusions: feasible as proposed; feasible with stated conditions, such as a signed utility agreement, pre-leasing, a smaller first phase, more collateral or a larger reserve; or not feasible as proposed, with the changes that would make it work.

    What is a data center feasibility study?

    It is an independent analysis, written for the lender's file, of whether a proposed or existing data center can support its financing. It covers power supply and its cost, demand for space and capacity, competing supply, the site and its permits, the building and its cost, the tenant or operator, the financing structure and the cash flow that pays the debt. For the difference between this kind of report and other documents in a loan file, see what makes a feasibility study bankable, feasibility study vs. appraisal and feasibility study vs. business plan.

    Lenders see five kinds of data center projects, and each shifts the weight of the study:

    1. Retail colocation. Many customers lease cabinets, cages or small suites and buy power, cooling, security and network access as a service.
    2. Wholesale colocation. Larger suites or whole halls leased to a few customers, often with power billed at or near cost.
    3. Enterprise data centers. Facilities a company builds or buys to run its own systems; the operating company's credit decides the loan.
    4. Edge sites. Small facilities close to users or network nodes, resting on latency, routes and a narrow local market.
    5. Powered and hyperscale shells. Buildings, sometimes with substations and cooling plant, delivered to one large user that installs its own equipment; the lease, the tenant's credit and the power contract carry the loan.

    The Lawrence Berkeley National Laboratory, in its 2024 report to Congress, sorts the same market into space types that run from small edge rooms to large-scale colocation and hyperscale modules. It modeled average module sizes of 11,000 square feet for large colocation spaces and 30,000 square feet for hyperscale facilities, measured per module rather than per campus [9].

    Exhibit 1. What the lender asks and what the study shows

    Lender questionWhat the study showsRule or test
    Is the operating business small enough for SBA?NAICS code, receipts and affiliates$40.0 million in receipts for NAICS 518210, computing infrastructure providers, data processing, web hosting and related services [42]
    Is the borrower an operator or a passive landlord?Services delivered, staff, control of operationsPassive businesses owned by developers and landlords that do not actively use or occupy the assets are ineligible [41]
    Does the owner use enough of the building?Rentable square feet by user60% occupancy of new construction with up to 20% leased; 51% of an existing building with up to 49% leased [41]
    Can business cash flow carry the debt?Operating cash flow against all business debt service1.15 on a historical or projected basis and 1:1 global; rental income from the project property stays out of the repayment analysis [43]
    Is the property limited or special purpose?Design, layout and alternative usesSBA's list is "not intended to be all-inclusive"; data centers are not named, so the study must argue the point either way [43]
    Does USDA require a study?Loan size and borrower historyRequired for Business and Industry guarantees greater than $1,000,000 to a new entity or new activity [44]
    Is the site rural, for USDA?Location against the population testOutside any city or town of more than 50,000 and its contiguous urbanized area [44]
    Will a large new facility harm existing competitors, for USDA?Demand against existing capacityB&I projects over $1 million that add more than 50 employees face a market capacity test [44]

    Source: 13 CFR Part 120 and 121.201 (revised as of January 1, 2026); SBA SOP 50 10 8.1; 7 CFR Part 5001 (revised as of January 1, 2026), as cited in each row.

    Many data center sites start as industrial land; the industrial feasibility study page covers the warehouse and plant tests that a powered shell shares.

    What does a lender need the study to prove?

    A lender needs proof that rent or operating cash flow repays the loan under the capital source's rules, and that the power supply, the site and the tenant do not break the projections. SBA's regulation states the standard plainly: "Loans must be so sound as to reasonably assure repayment" [41]. The same regulation allows SBA to require "a survey, or a feasibility study" [41].

    SBA's procedures name the situations that may prompt it to ask for a study. Three fit data centers closely: a "highly specialized Project property", a "project size disproportionate to size of community it will serve" and "market saturation by industry type and location" [43]. The procedures also say that independent reports "may be beneficial in mitigating any weaknesses identified in the credit analysis" [43]. USDA goes further. For Business and Industry guarantees above $1,000,000 to a new entity or new activity, a study by an independent qualified consultant acceptable to the Agency is required, and the Agency defines the study as an evaluation of "economic, market, technical, financial, and management feasibility" [44]. A summary of how bank regulators, SBA and USDA each treat these reports is in lender feasibility study requirements.

    For a data center, the proof falls into five questions:

    1. Power. Will the utility deliver the capacity on the date the projections need it, under which tariff, with what minimum bill, collateral and exit terms?
    2. Demand. Who will lease or use the capacity, at what rent per kilowatt, and how fast?
    3. Supply. What competing capacity is operating, under construction or holding a utility commitment in the same market?
    4. Cost and timing. What will the building, the electrical and cooling plant and the network connections cost, and when can each be energized?
    5. Coverage. After power, operating costs and reserves, does cash flow cover debt service in the base case and in the downside cases the lender cares about?

    The weight shifts with the project type: absorption and the utility schedule for speculative colocation; the lease, tenant credit and re-leasing case for a powered shell; the operating company's need and cost savings for an enterprise facility.

    How fast is data center construction growing?

    Faster than any other private nonresidential category Census tracks. Census reports data center construction as its own line inside the office category, and the series starts in 2014. In September 2014 the seasonally adjusted annual rate was $1,922 million. By September 2026 it was $96,462 million, about 50 times larger, and up 90.3% from September 2025 [1].

    Exhibit 2. Private data center construction, September of each year, 2014 to 2026

    September ofData center ($ million, SAAR)Office total incl. data center ($ million)Data center share of officeWarehouse ($ million)Manufacturing ($ million)
    20141,92240,6994.7%15,43461,635
    20152,80048,7985.7%17,79186,539
    20164,22063,2416.7%23,24677,125
    20174,68658,0718.1%29,99568,197
    20186,28768,5409.2%33,42074,308
    20198,12079,57210.2%36,37181,128
    202010,10179,38312.7%41,62072,990
    202110,83477,48414.0%54,20982,572
    202214,57185,83717.0%76,314138,747
    202321,28587,80024.2%79,979204,657
    202437,57692,14740.8%64,254249,116
    202550,700104,37648.6%56,118203,744
    2026 (preliminary)96,462145,63366.2%51,615167,226

    Source: U.S. Census Bureau, Value of Private Construction Put in Place, seasonally adjusted annual rate, release of November 2, 2026 [1]. Shares calculated by FSC.

    Two things stand out. First, data centers are now two-thirds of private office construction by value. A lender who reads "office construction is rising" in a national summary is mostly reading data center spending. Second, the other industrial categories moved the other way. Warehouse construction fell 35.5% from September 2023 to September 2026, and manufacturing construction fell 32.9% from its September 2024 level [1]. Capital, contractors and electrical equipment have shifted toward data centers.

    The pace accelerated through 2026. Spending rose 73.9% from December 2025 to September 2026, with monthly gains of 10% or more in June, July and August [1].

    Exhibit 3. Private data center construction by month, December 2025 to September 2026

    MonthData center ($ million, SAAR)Change from prior month
    Dec-2555,461
    Jan-2656,211+1.4%
    Feb-2657,361+2.0%
    Mar-2658,121+1.3%
    Apr-2661,859+6.4%
    May-2665,688+6.2%
    Jun-2672,695+10.7%
    Jul-26 (revised)80,718+11.0%
    Aug-26 (revised)88,815+10.0%
    Sep-26 (preliminary)96,462+8.6%

    Source: U.S. Census Bureau, Value of Private Construction Put in Place, seasonally adjusted annual rate, release of November 2, 2026 [1]. Changes calculated by FSC; recent months will be revised.

    Construction spending measures money going into the ground, not demand being met. For a specific market the study asks whether new supply is already leased or owner-built, whether equipment and labor will be available on schedule, and whether earlier projects will claim the utility's capacity first.

    How big is the data processing and hosting industry, and where is it?

    County Business Patterns counted 18,544 establishments and 629,527 mid-March employees in NAICS 518210 in 2023, with annual payroll of $92.96 billion [2]. That industry code, retitled in the 2022 NAICS as computing infrastructure providers, data processing, web hosting and related services, is the one SBA uses for the size standard in Exhibit 1 [42]. It counts business establishments classified by their main activity, not buildings. A colocation operator, a hosting firm and a cloud computing operation can all fall in it, and the count can miss facilities run by companies whose main business is something else. The panel is still the best public measure of where the industry employs people.

    Most establishments are small. Two in three have fewer than 10 employees, and only 526 have 250 or more [2].

    Exhibit 4. NAICS 518210 establishments by employment size class, United States, 2023

    Employment size classEstablishmentsShare of establishments
    Fewer than 510,29455.5%
    5 to 92,38612.9%
    10 to 191,97510.7%
    20 to 491,7249.3%
    50 to 999054.9%
    100 to 2497344.0%
    250 to 4993121.7%
    500 to 9991380.7%
    1,000 or more760.4%
    All establishments18,544100.0%

    Source: U.S. Census Bureau, County Business Patterns 2023, cbp23us, NAICS 518210 [2]. Shares calculated by FSC.

    Employment is concentrated. California alone holds 19.7% of the industry's employees, and five states (California, Texas, New York, Virginia and Florida) hold 45.1% [3]. Payroll per employee varies widely among the leading states, from $111,869 in North Carolina and $112,836 in Pennsylvania to $247,172 in New York, which reflects the mix of engineering, software and facility jobs counted in each state.

    Exhibit 5. Top 12 states by NAICS 518210 employment, 2023

    RankStateEstablishmentsEmployeesAnnual payroll ($ million)Payroll per employee ($)
    1California2,698123,85926,183.6211,398
    2Texas1,41256,2906,958.7123,623
    3New York1,01339,7309,820.2247,172
    4Virginia64133,4044,842.6144,970
    5Florida1,26630,3853,717.7122,355
    6Massachusetts51027,9054,655.8166,846
    7Georgia56726,2303,158.0120,396
    8Illinois62721,9342,635.1120,139
    9Pennsylvania93719,4432,193.9112,836
    10New Jersey59518,6322,614.2140,309
    11Colorado55417,6892,393.8135,325
    12North Carolina45017,2411,928.7111,869

    Source: U.S. Census Bureau, County Business Patterns 2023, cbp23st, NAICS 518210, all legal forms [3]. Payroll per employee calculated by FSC.

    A study uses these counts in three ways. They show whether a market has the trained workforce a facility needs to staff around the clock. They help size the local base of hosting and network businesses that lease retail colocation. And county-level counts, from the same dataset, give a first read on whether an edge site's local market is real or thin. They do not measure megawatts, and a study should never treat employment as a proxy for capacity.

    How much electricity do data centers use?

    About 176 TWh in 2023, or 4.4% of all U.S. electricity, according to the Lawrence Berkeley National Laboratory report released by the Department of Energy in December 2024 [8][9]. Use was flat at about 60 TWh from 2014 to 2016, reached 76 TWh in 2018 and then more than doubled between 2017 and 2023 as servers with graphics processors for artificial intelligence spread through the installed base [9].

    Exhibit 6. U.S. data center electricity use, 2014 to 2028

    YearElectricity useShare of U.S. electricityNote
    201458 TWhn/a in releaseStart of the estimate series [8]
    2014 to 2016about 60 TWh per yearn/aFlat, continuing a minimal growth trend [9]
    2018about 76 TWh1.9%Server base and accelerated servers start growing [9]
    2023176 TWh4.4%More than double the 2017 level [8][9]
    2028, low scenarioabout 325 TWh6.7%Scenario, not a forecast of one outcome [9]
    2028, high scenarioabout 580 TWh12.0%Equal to 74 to 132 GW of demand across the range at 50% capacity utilization [9]

    Source: U.S. Department of Energy release of December 20, 2024 [8]; Lawrence Berkeley National Laboratory, 2024 United States Data Center Energy Usage Report [9].

    The 2028 range is wide on purpose. The laboratory built it from scenarios for chip shipments, how hard the installed servers run and how they are cooled [9]. A study should cite the range, not a point inside it, and should not use a national range to justify demand in one market. What the range does tell a lender is that the national load is large enough to strain transmission and generation in the places where data centers cluster. The Department of Energy said as much in its September 2025 request for information, describing data centers and other large loads that "are driving multi-gigawatt increases in electric demand" [17].

    Power usage effectiveness (PUE) is the ratio of all the power a facility draws to the power its IT equipment uses. A PUE of 1.40 means the building draws 1.4 kilowatts for every kilowatt delivered to servers, storage and network gear; the extra 0.4 goes to cooling, power conversion, lighting and losses. The laboratory estimates that the national average PUE fell from 1.6 in 2014 to 1.4 in 2023, largely because more servers moved into larger hyperscale and colocation buildings [9].

    Exhibit 7. Efficiency and water estimates for U.S. data centers

    MeasureValuePeriod
    Average PUE, all U.S. data centers1.62014 [9]
    Average PUE, all U.S. data centers1.42023 [9]
    Average PUE, hyperscale and colocationunder 1.4, with around 75% of servers in those facilities2023 [9]
    Average PUE, scenario range1.15 to 1.352028 [9]
    Direct water consumption, all data centers21.2 billion liters, 64% in internal data centers2014 [9]
    Direct water consumption, all data centers66 billion liters, 84% in hyperscale and colocation, 12% internal2023 [9]
    Direct water consumption, hyperscale only60 to 124 billion liters2028 scenario [9]
    Indirect water footprint through electricity generationnearly 800 billion liters2023 [9]

    Source: Lawrence Berkeley National Laboratory, 2024 United States Data Center Energy Usage Report [9].

    Two cautions belong in any study that leans on a design PUE. The laboratory's figures come from simulations that "assume systems are commissioned and operate as designed", and the report adds: "This is rarely the case" [9]. Its simulations also assumed uninterruptible power supply efficiencies as low as 77% to 85% for small spaces [9]. A study should test the cash flow at a PUE worse than design, at least through the first years of operation when halls are partly filled and cooling plant runs below its best point.

    Is power available, and on what terms?

    Power availability is a finding, not an assumption. The study must show, from the utility's own documents, how much capacity the site can draw, from what date, under which tariff and on what conditions. A letter that says a utility is "studying" a request is not a capacity commitment, and the study should say so in plain words.

    The power section of a data center study answers these questions:

    1. Capacity and date. What load will the utility serve, in what steps and from what dates, and which upgrades must finish first?
    2. Tariff and contract. Which rate schedule applies, with what minimum bill, term, ramp, exit fee or collateral (Exhibit 10)?
    3. Cost responsibility. Who pays for the substation, line extension and network upgrades, and when?
    4. Queue position. Where does the project sit among other large loads seeking the same capacity?
    5. Backup supply. What generators, batteries or on-site generation are planned, under which permits and limits?
    6. Price path. What will the delivered price be, including demand charges and riders?

    Public data can frame the utility's answers. EIA's state tables show where retail electricity sales and generating capacity are growing fastest. Commercial-sector retail sales rose 3.3% nationally in the first eight months of 2026 compared with the same period of 2025, but 14.4% in Ohio, 14.2% in Arizona, 13.8% in Indiana and 18.4% in Nebraska [5]. Data centers are not the only cause, and EIA does not break them out, but a lender should expect the utility in a fast-growing state to be writing tighter large-load terms.

    Exhibit 8. Largest increases in commercial retail electricity sales, January to August 2026 vs 2025

    RankStateCommercial sales, YTD Aug 2025 (thousand MWh)Commercial sales, YTD Aug 2026 (thousand MWh)Change (thousand MWh)Change (%)
    1Texas115,429124,9869,557+8.3%
    2Ohio37,95443,4125,458+14.4%
    3Arizona25,05828,6233,565+14.2%
    4Georgia38,40740,9602,553+6.6%
    5Indiana16,85519,1772,322+13.8%
    6Nebraska9,81311,6151,802+18.4%
    7Virginia58,06159,5921,531+2.6%
    8Florida67,42468,8521,428+2.1%
    9Oklahoma18,22919,167938+5.1%
    10South Carolina17,99518,887892+5.0%
    11Utah9,84610,602756+7.7%
    12North Carolina34,20234,939737+2.2%
    United States1,007,4971,041,10433,607+3.3%

    Source: U.S. Energy Information Administration, Electric Power Monthly, Table 5.4.B, data through August 2026, released October 23, 2026 [5][7]. Changes calculated by FSC.

    A note on reading this table: EIA reports sales by the sector each utility assigns a customer to. A data center may be billed as a commercial or an industrial customer depending on the utility and the tariff, so the study should confirm the rate class with the utility rather than infer it from the table. Virginia's commercial sales rose only 2.6% from a much larger base; the absolute increase still ranks seventh.

    Generating capacity is moving too. Net summer capacity from all sources rose 57,152.5 MW nationally between August 2025 and August 2026, and Texas alone added 16,238.0 MW, 28.4% of the national gain [6].

    Exhibit 9. Largest increases in net summer generating capacity, August 2025 to August 2026

    RankStateNet summer capacity, Aug 2025 (MW)Net summer capacity, Aug 2026 (MW)Change (MW)
    1Texas177,859.3194,097.316,238.0
    2Arizona36,048.841,591.15,542.3
    3New Mexico12,670.017,545.24,875.2
    4California100,211.4104,232.74,021.3
    5Oklahoma32,236.434,422.32,185.9
    6Florida73,068.075,067.41,999.4
    7Indiana30,142.531,912.61,770.1
    8Illinois47,102.448,735.71,633.3
    9Ohio31,528.533,157.31,628.8
    10Colorado20,186.621,780.61,594.0
    11Michigan32,873.634,150.11,276.5
    12Massachusetts11,718.312,758.91,040.6
    United States1,261,656.51,318,809.057,152.5

    Source: U.S. Energy Information Administration, Electric Power Monthly, Table 6.2.A, utility-scale units, all sources, August 2026 and 2025 [6]. Changes calculated by FSC.

    New capacity in a state does not mean deliverable capacity at a site. Transmission between new generation and a substation near the project can be the binding limit, and that is a question only the utility and the grid operator can answer. The table tells a lender where to expect more supply over time; the utility letter tells the lender what the project can actually draw.

    What do large-load tariffs require from a data center?

    They shift the cost and risk of serving a very large new customer onto that customer. Since January 2025, regulators in at least four states have approved terms that apply above a load threshold, lengthen contracts, set minimum bills and require collateral. A study must read the project's actual tariff, but the pattern is consistent enough that a lender can expect these items.

    Exhibit 10. Large-load terms approved or adopted by state regulators

    State and actionThresholdContract termMinimum billCollateral and exitDate
    Georgia: rule for Georgia PowerMore than 100 MWLonger contracts allowed, from 5-year to 15-yearMinimum billing allowed for high-load customersContracts with customers in the 100 MW category filed with the Commission for reviewJanuary 23, 2025 [18]
    Kansas: Evergy Large Load Power Service75 MW or more of new peak load, or an expansion of 75 MW12 years minimum plus up to 5 years of ramp, 17 years in total80% of contract demand, regardless of actual usageCollateral equal to two years of minimum bills; early exit pays all remaining minimum billsNovember 6, 2025 [19]
    Missouri: Ameren Missouri and Evergy tariffs under 2025 Senate Bill 4Large-load customers as defined in each tariff12 years minimum plus optional 5-year ramp, up to 17 yearsDemand charge set at 80% of the agreed rateTwo years of minimum bills; 24 months' notice to exit, with an exit feeFact sheet April 2026 [20][21]
    Pennsylvania: model large-load tariffMore than 50 MW individually or 100 MW in aggregateGuidance on ramp schedules, minimum terms and exitLeft to each utility's tariff filingDeposits and collateral against stranded costs; studies within six monthsFinal order released May 13, 2026 [22]
    Missouri: Liberty UtilitiesPendingPendingPendingCase ET-2026-0184 in progress2026 [20]
    Federal: Ratepayer Protection PledgeLarge data center users that signedSeparate rate structures negotiated with utilities and statesPay rates "whether they use the electricity or not"Pay for new power delivery upgradesMarch 4, 2026 [11]

    Source: Georgia Public Service Commission [18]; Kansas Corporation Commission [19]; Missouri Public Service Commission [20][21]; Pennsylvania Public Utility Commission [22]; Proclamation 11014, 91 FR 11439 [11]. The pledge is a voluntary commitment, not a tariff.

    The pledge deserves a short explanation because lenders ask about it. Proclamation 11014 records that on March 4, 2026, seven technology companies accepted the terms of a "Ratepayer Protection Pledge" [11]. Under it, those companies say they will build, bring or buy new generation, "pay for all new power delivery infrastructure upgrades to service their data centers" and pay negotiated rates and infrastructure costs "whether they use the electricity or not" [11]. The pledge binds the companies that signed it. It does not change any utility's tariff, and it does not bind a developer, a colocation operator or a smaller user. A study for a project leased to a signatory should still read the actual utility agreement.

    What these terms mean for the cash flow:

    • Minimum bills become fixed costs. An 80% minimum on contracted demand in Kansas, or a demand charge set at 80% of the agreed rate in Missouri, is owed whether or not the halls fill on schedule [19][21]. In a colocation model, that cost sits with the operator until tenants arrive, unless the leases pass it through.
    • Collateral ties up equity. Two years of minimum bills in Kansas and Missouri is a cash or credit commitment that belongs in sources and uses [19][21].
    • Contract terms outlast many leases. A 17-year utility commitment can run longer than the first lease term of a wholesale tenant. The study should show who carries the minimum bill if that tenant leaves.
    • Exit costs are large. In Kansas an early exit pays every remaining minimum bill; in Missouri the customer must give 24 months' notice and pay an exit fee [19][21].
    • Thresholds matter by phase. A small first phase may fall below a threshold that later phases cross.

    How are FERC co-location and large-load proceedings changing interconnection?

    They are moving the rules for connecting large loads, including loads that sit next to a power plant, from case-by-case negotiation toward written tariff terms. Most retail service terms remain with states, but where a data center connects to the interstate transmission system or shares a site with a generator, federal proceedings now matter to the schedule and the cost.

    Exhibit 11. Federal proceedings on large loads and co-location, 2024 to 2026

    DateActionDocket or citation
    November 1, 2024FERC holds a Commissioner-led technical conference on large loads co-located at generating facilitiesAD24-11-000 [13]
    February 20, 2025FERC issues an order instituting a section 206 investigation of whether the PJM tariff is unjust and unreasonable as it relates to co-located loadEL25-49-000, with AD24-11-000 and EL25-20-000 [12]
    July 23, 2025Executive Order 14318 directs faster federal permitting for data center projects above 100 MW of new load90 FR 35385 [10]
    September 18, 2025DOE asks for large generation and transmission projects that enable at least 3 GW of incremental load; responses due November 21, 202590 FR 45032 [17]
    October 23, 2025The Secretary of Energy proposes an advance notice of proposed rulemaking on interconnection of large loads, including loads sharing a point of interconnection with generationRM26-4-000 [15]
    November 21 and December 5, 2025Comment and reply comment periods endRM26-4-000 [15]
    February 24 to 25, 2026FERC staff may attend the reliability organization's Emerging Large Loads Technical Conference91 FR 8213 [16]
    June 18, 2026FERC open meeting agenda lists RM26-4-000 (item E-1) and EL25-49-002 (item E-2)91 FR 36126 [14]
    August 14, 2026FERC's published regulatory agenda lists the next action in RM26-4 as undetermined, 11/00/2691 FR 53150 [15]

    Source: Federal Register, as cited in each row [10][12][13][14][15][16][17].

    The regulatory agenda describes the rulemaking's aim as reforms that would "standardize interconnection procedures and agreements" for large loads, "including those seeking to share a point of interconnection with new or existing generation facilities" [15]. Until a final rule or tariff change takes effect in the project's region, the study should treat interconnection terms as the ones in the utility's and grid operator's current documents, and it should name the open dockets that could change them. The study should also say whether the project relies on co-location with a generator, because that structure has been under active review in the largest regional market since February 2025 [12].

    Executive Order 14318 is a permitting order, not a power order. It defines a "Data Center Project" as a facility that "requires greater than 100 megawatts (MW) of new load dedicated to AI inference, training, simulation, or synthetic data generation" [10]. It sets up an initiative to support qualifying projects, steers agencies toward categorical exclusions under the National Environmental Policy Act, directs EPA to identify brownfield and Superfund sites for these projects, and revokes Executive Order 14141 of January 14, 2025 [10].

    Exhibit 12. Executive Order 14318 definitions that a study may need to apply

    TermDefinition or rule in the order
    Data Center ProjectGreater than 100 MW of new load dedicated to AI inference, training, simulation or synthetic data generation [10]
    Qualifying Project, capital testA project for which the sponsor has committed at least $500 million in capital expenditures [10]
    Qualifying Project, load testAn incremental electric load addition of greater than 100 MW [10]
    Federal financial assistanceAssistance below 50 percent of total project costs is presumed not to be substantial federal control under NEPA [10]
    FAST-41 transparencyQualifying projects may be designated within 30 days of identification to the permitting council [10]
    Endangered Species ActProgrammatic consultation covering common construction activities over the next 10 years [10]

    Source: Executive Order 14318 of July 23, 2025, 90 FR 35385 [10].

    Most projects financed with SBA or USDA support are far below these thresholds. The order matters to them mainly through the faster environmental reviews and the brownfield guidance it calls for. For larger projects, the study should say whether the project meets a qualifying test and what federal permits it actually needs.

    How do power price and PUE change the cash flow?

    Directly and in proportion. Annual energy cost equals the IT load, times PUE, times 8,760 hours, times the price per kilowatt-hour. Every one of those terms is a study input, and two of them, PUE and price, are where optimistic projections hide.

    State average prices give a starting range, not a site price. In the first eight months of 2026 the average industrial price ran from 5.19 cents per kilowatt-hour in New Mexico to 37.83 cents in Hawaii, against a national average of 9.09 cents, up 6.9% from 8.50 cents a year earlier [4]. The national commercial average was 14.04 cents, up 5.6% [4].

    Exhibit 13. The 12 states with the lowest average industrial electricity price, January to August 2026

    RankStateIndustrial, YTD Aug 2026Industrial, YTD Aug 2025Commercial, YTD Aug 2026Commercial, YTD Aug 2025
    1New Mexico5.196.0210.9611.06
    2Louisiana6.586.3311.7611.29
    3Texas6.776.318.608.59
    4Tennessee6.846.7513.5712.99
    5Oklahoma6.896.109.359.04
    6Arkansas6.966.7111.5510.68
    7Montana6.997.1012.8911.72
    8Washington7.176.9511.8610.84
    9Kentucky7.496.8412.6411.73
    10Mississippi7.657.2614.0013.15
    11Iowa7.667.2711.6611.00
    12South Carolina7.867.2711.8611.13
    United States9.098.5014.0413.29

    Source: U.S. Energy Information Administration, Electric Power Monthly, Table 5.6.B, average price to ultimate customers in cents per kilowatt-hour, year to date through August 2026 and 2025 [4].

    State averages blend many customers, from small plants to large contract loads. A data center's delivered price depends on its tariff, its load factor, demand charges, riders and any special contract. The study should build the price from the tariff sheets and the utility's terms, then show what happens if it rises. In the calculator's default case, each one-cent increase in the price adds $637,728 a year in energy cost for 8 MW leased at 70% average draw and a PUE of 1.30.

    Who pays the energy bill matters as much as its size. When leases pass power through at cost, the tenant carries price and PUE risk; when contracts bundle power into a fixed charge, the operator does. The study models the lease structure the operator will actually sign.

    The calculator below tests this arithmetic. It turns leased megawatts, average IT draw, PUE and power price into annual energy cost, then adds rent per kilowatt per month and the share of energy cost recovered from tenants to reach net operating income and a debt service coverage ratio. It also solves for the rent needed to hit a target coverage. Its inputs are illustrative defaults chosen to make the arithmetic easy to follow, not market figures, and its result is not a feasibility conclusion. For how SBA and USDA define and test coverage, see debt service coverage ratio for SBA and USDA loans.

    Power cost and coverage check

    Every default is an illustrative assumption you control, not market data. None is a quoted rent, a utility rate or a lender requirement. The check uses 8,760 hours a year and holds IT draw, PUE and power price constant; it leaves out demand charges, minimum bills, taxes, reserves, capital expenditures and lease-up timing.

    Illustrative inputs

    Inputs are illustrative. Replace them with the project's own contracted rents, the utility's tariff, the design PUE and the lender's term sheet. The result is arithmetic, not a feasibility conclusion.

    Average IT load / facility load (MW)5.60 / 7.28
    Annual facility energy (MWh)63,772.8
    Annual energy cost$5,101,824
    Annual rent$14,400,000
    Energy cost recovered from tenants$0
    Net operating income$7,298,176
    Coverage (NOI divided by annual debt service)1.22x: covers debt service but is below the target
    Rent needed for 1.25x coverage ($ per kW per month)$152.10
    Energy cost per leased kW per month$53.14
    Leased share of capacity built80%

    Illustrative inputs. The result is arithmetic from the inputs above, not a feasibility conclusion. A feasibility study replaces these inputs with the project's contracted rents, the utility's tariff, the design PUE and the lender's terms.

    How is demand measured for colocation, enterprise, edge and hyperscale projects?

    By the capacity tenants will contract for, in kilowatts or megawatts of critical IT load, and by the rent they will pay per kilowatt per month. Square feet matter for the building budget; kilowatts matter for revenue. A demand section that counts square feet and applies an office-style rent per square foot has measured the wrong thing.

    The evidence differs by project type:

    Exhibit 14. What demand evidence looks like for each kind of data center

    Project typePrimary demand evidenceWhat the study testsMain demand risk
    Retail colocationLocal enterprises, network operators and hosting firms; existing operators' occupancy; pricing for cabinets and cagesAbsorption in kW per year, churn, cross-connect revenue, sales capacitySlow lease-up and price competition from newer buildings
    Wholesale colocationSigned or advanced leases for suites or halls; tenant credit; renewal and expansion rightsLease terms against the utility contract and debt term; pass-through of powerConcentration in one or two tenants
    Enterprise facilityThe owner's own computing needs and the cost of leasing elsewhereWhether owning lowers cost or risk compared with colocation or cloud servicesChange in the owner's strategy or technology
    Edge siteLatency needs of nearby users, carrier routes, local business and population baseWhether a small market can fill a small building at a viable rentA thin market and a single anchor customer
    Powered or hyperscale shellA lease or commitment from one large user; utility capacity reserved for the siteTenant credit, lease term, termination rights, power delivery dateTenant exit, delay in energization, re-leasing a specialized building

    Source: FSC method; space types follow Lawrence Berkeley National Laboratory, 2024 United States Data Center Energy Usage Report [9].

    For speculative colocation, the market survey is the heart of the demand section. It identifies every operating and planned facility within the competitive area, its capacity in critical megawatts, its occupancy where it can be learned, and its power status. Planned supply is sorted into four groups: under construction with power secured, under construction without a power date, announced with a utility commitment, and announced without one. Only the first two belong in the near-term supply forecast; the others are risks to rent and lease-up later.

    Absorption is then estimated in kilowatts per year, from the leasing history of comparable buildings and from tenants in the market that are known to be seeking space. The study converts absorption into a lease-up schedule for the subject, net of the supply that will deliver at the same time. If the schedule needs the subject to capture a larger share of absorption than its quality, location and power date support, the study says so.

    How does the study test a single-tenant hyperscale lease?

    As a credit exposure first and a real estate question second. When one tenant leases the whole building, the loan is repaid by that tenant's rent until the lease ends or the tenant leaves. The study reads the lease and the tenant's financial condition with the same care a lender would give a corporate borrower.

    The lease review covers:

    • Term and options. A lease shorter than the loan's amortization leaves a re-leasing gap the study must price.
    • Rent and escalations. Rent per kilowatt, escalators and which costs the tenant pays directly.
    • Commencement. A rent start tied to energization moves the utility's schedule into the lender's cash flow.
    • Termination and contraction. Early exit, give-back of capacity and remedies for late delivery.
    • Assignment and guarantee. Whether a parent guarantees the lease and whether it can pass to a weaker affiliate.

    The coverage test is then run twice: with the tenant paying under the lease, and with the tenant gone at the earliest date it could leave. In the second case the study estimates downtime, re-leasing cost and the rent a new tenant would pay for a building designed around another company's equipment. If the building is so specialized that re-leasing is not realistic, the study says the loan depends entirely on the tenant's credit, and the lender can decide on that basis.

    The utility contract must line up with the lease. If the landlord signs a 17-year utility commitment with an 80% minimum bill, as in the Kansas tariff, and the tenant's lease runs 10 years, someone carries that minimum for seven years after the lease ends [19]. The study names that party.

    What site, fiber, water and zoning issues decide feasibility?

    Five site issues decide most data center files: power delivery, fiber routes, water and cooling, zoning and community approval, and environmental condition. Power is covered above. The other four are below.

    Fiber and latency. Tenants need diverse routes, more than one carrier and, for retail colocation and edge sites, low latency. The study maps the routes, the carriers, the cost and time to build laterals and whether routes are physically separate; signed carrier commitments outweigh discussions.

    Water and cooling. Cooling design sets both the PUE and the water draw. The laboratory found that direct water use by U.S. data centers rose from 21.2 billion liters in 2014 to 66 billion liters in 2023, with hyperscale and colocation facilities using 84% of the 2023 total [9]. It found that water-cooled chiller systems without economizers show the highest water use, and that airside economizers allow chilled water systems to shut down in good weather [9]. The study checks the water supply, the utility's capacity and charges, any local limits on consumption and the trade-off between water and power in the chosen design.

    Zoning and community process. The study confirms whether the use is permitted by right, conditional or in need of rezoning, and lists the approvals still required: site plan, building, stormwater, generator air permits and utility easements. Local concerns usually center on noise, building mass, water, construction traffic, tax revenue and grid capacity. The study reports hearings ahead and conditions accepted; it does not predict how an open public process will end.

    Environmental condition and reuse sites. Former industrial and utility sites often come with power and transmission nearby, which is why they attract data centers. Executive Order 14318 directs EPA to identify brownfield and Superfund sites for qualifying projects and to issue guidance within 180 days to speed their reuse [10]. A study for a reuse site reads the environmental reports, the remediation status and any land-use limits recorded against the property.

    Which environmental permits apply to backup generators?

    Two federal rules govern most diesel backup engines at data centers: the new source performance standards for stationary compression ignition engines (40 CFR Part 60, Subpart IIII) and the national emission standards for stationary reciprocating engines (40 CFR Part 63, Subpart ZZZZ). Both treat an engine as an emergency engine only if it stays within strict operating limits [35][39].

    Exhibit 15. Federal rules that bind data center backup engines

    RuleWhat it saysCitation
    Who is covered by Subpart IIIIOwners and operators of stationary compression ignition engines that commence construction after July 11, 2005, and are manufactured after April 1, 2006 (non-fire-pump engines)40 CFR 60.4200 [33]
    Emission standardsEmergency engines of model year 2007 and later with displacement under 30 liters per cylinder meet the nonroad engine standards for their model year and power40 CFR 60.4205 [34]
    Emergency useNo time limit on use in emergency situations40 CFR 60.4211(f)(1) [35]
    Maintenance and testingUp to 100 hours per calendar year40 CFR 60.4211(f)(2) [35]
    Non-emergency useUp to 50 hours per year, counted within the 100; not for peak shaving or non-emergency demand response, except limited dispatch by the local balancing authority or distribution operator to avert local outages40 CFR 60.4211(f)(3) [35]
    Emergency engine definitionEngines that provide power for critical networks or equipment when utility power is interrupted, and that meet the operating limits40 CFR 60.4219 [36]
    Who is covered by Subpart ZZZZStationary engines at major sources (10 tons per year of one hazardous air pollutant or 25 tons of all combined) and at area sources40 CFR 63.6585 [37]
    New engines at area sourcesMeet Subpart ZZZZ by meeting Subpart IIII; no further requirements under Part 6340 CFR 63.6590(c) [38]
    ZZZZ operating limitsThe same 100-hour and 50-hour framework for emergency engines40 CFR 63.6640(f) [39]

    Source: 40 CFR Parts 60 and 63 (revised as of July 1, 2025), as cited in each row; definition of emergency stationary RICE at 40 CFR 63.6675 [40].

    These limits drive three parts of a study. First, the operating plan: a design that counts on running generators to shave peaks, sell power to the grid or sit out utility curtailments for long periods may lose emergency status and fall under the much stricter non-emergency standards [35]. Second, the permit: the number and size of engines can push a campus toward major-source status, which brings permitting cost and time. Third, the utility contract: if a tariff or service agreement asks the facility to curtail during grid emergencies, the study must check that the curtailment plan fits the engine limits. State and local air permits add their own conditions, which the study lists for the site.

    What state tax incentives apply to data center equipment?

    Many states exempt data center equipment, and sometimes electricity, from sales and use tax, but only for projects that meet investment, job and wage tests. The exemptions are large enough to change the equipment budget and the operating budget, so the study confirms which tests the project meets and when.

    Exhibit 16. Data center sales and use tax incentives in eight states

    StateWhat is exempt or abatedInvestment testJobs and wagesPeriod
    VirginiaComputer equipment and enabling software, including chillers and backup generators$150 million new capital investment ($70 million in distressed localities)50 new jobs (10 in distressed localities) at 1.5 times the local prevailing wageJuly 1, 2010 to June 30, 2035; extensions to 2040 at $35 billion and 1,000 jobs, and to 2050 at $100 billion and 2,500 jobs [23]
    NevadaPartial abatement of property tax and local school support (sales) tax$25 million within 5 years (up to 10 years of abatement); $100 million (10 to 20 years)10 or 50 Nevada-resident full-time employees; wages at least 100% of the statewide averageOperation of at least 10 years; statute effective through December 31, 2056 [24]
    MinnesotaEnterprise IT equipment and software25,000 square feet and $30 million within 48 months; $50 million within 24 months for refurbished; $250 million within 60 months for large-scale centers after June 30, 2025Large-scale centers must certify a sustainable design or green building standard within three years of servicePurchases within 35 years of the first; certification before July 1, 2042 [25]
    MissouriState and local sales and use tax on utilities, equipment and construction materials (data storage centers, NAICS 518210)New: $25 million within 36 months; expanding: $5 million within 12 monthsNew: 10 jobs; expanding: 5 jobs; both at 150% of county average wageUp to 15 years (new) or 10 years (expanding), capped by projected net fiscal benefit [26]
    North CarolinaElectricity and datacenter support equipment, including substations, generators, transformers and UPS systems$75 million in private funds within five yearsCounty development-tier wage standard and health insuranceWhile conditions are met [27][28]
    IowaComputers, cooling and power infrastructure; backup fuel and electricity, time-limited for new construction after June 6, 2025$200 million within the first six yearsRegistration with the department; state sustainable design and construction standardsElectricity and fuel: first 10 years in cities over 30,000, first 15 years elsewhere [29]
    GeorgiaHigh-technology data center equipment$25 million, $75 million or $250 million, depending on county population (thresholds changed May 9, 2022)Average number of new quality jobs during the investment periodPer the certificate and Rule 560-12-2-.117 [30][31]
    ArizonaTax relief for certified computer data centers and qualified colocation tenants$25 million in counties of 800,000 or fewer; $50 million in larger counties, within five yearsColocation tenants must use at least 500 kW for two or more yearsThrough the tenth full calendar year after certification; twentieth for sustainable redevelopment projects of $200 million or more [32]

    Source: Code of Virginia 58.1-609.3 [23]; NRS 360.754 [24]; Minnesota Statutes 297A.68, subd. 42 [25]; RSMo 144.810 [26]; N.C. G.S. 105-164.13(55a) and 105-164.3(201) [27][28]; Iowa Code 423.3(95) [29]; Georgia Department of Revenue [30][31]; A.R.S. 41-1519 [32]. Summaries; read the statute for every condition.

    Four points keep these incentives from distorting a study:

    1. They are earned, not assumed. Most require a certificate or agreement and can be clawed back if targets are missed; the study shows the cost if the project falls short.
    2. They follow the equipment buyer. Virginia applies the exemption to the operator and its tenants if they meet the tests together [23]. Arizona extends relief to qualified colocation tenants [32]. A colocation study must show which party buys which equipment, because a tenant's exemption does not reduce the operator's budget.
    3. They change over time. Iowa narrowed the electricity and fuel exemptions for construction completed on or after June 6, 2025 [29]. Minnesota added a large-scale tier for investment periods starting after June 30, 2025 [25]. The study cites the version in force on its date.
    4. Local taxes still apply. Property taxes and local abatement agreements vary by county and city.

    How do depreciation rules affect a data center budget?

    They change after-tax cash flow, not the debt service coverage most lenders test, but they matter to equity and to an owner-operator's projections. Federal law treats a data center as two very different asset classes: the building and its structural components, recovered over 39 years, and servers and other computer equipment, which are 5-year property as qualified technological equipment [45]. Public Law 119-21 made the 100 percent special depreciation allowance permanent for property acquired after January 19, 2025 [46].

    Exhibit 17. Federal recovery rules that apply to data center assets

    AssetTreatmentCitation
    Building shell and structural components39-year nonresidential real property26 U.S.C. 168(c) [45]
    Servers, storage and other computers5-year property as qualified technological equipment26 U.S.C. 168(e) and (i) [45]
    Definition of computerA programmable electronically activated device that accepts information, applies processes and supplies results26 U.S.C. 168(i) [45]
    Special allowance for qualified property100 percent, made permanentPublic Law 119-21, section 70301 [46]
    Effective dateProperty acquired after January 19, 2025, subject to the written binding contract rulePublic Law 119-21, section 70301(c) [46]
    Transition election40 percent (or 60 percent for longer-production property) instead of 100 percent for the first taxable year ending after January 19, 2025Public Law 119-21, section 70301 [46]

    Source: 26 U.S.C. 168 (2024 edition) [45]; Public Law 119-21 [46]. Cost segregation and the classification of electrical and mechanical plant are matters for the owner's tax adviser.

    For a study, the practical point is the replacement cycle. Servers and network gear owned by an operator wear out and become obsolete far faster than the building. A projection that shows strong cash flow but no reserve for replacing owned equipment overstates what is available for debt service over a long loan.

    Which financing paths fit a data center?

    It depends on the borrower and the size. Most large data centers are financed with conventional construction loans, private credit or the balance sheets of their owners and tenants, and those lenders set their own terms. Government-guaranteed programs fit a narrower set: operating businesses that own their facilities, smaller colocation and hosting firms, edge sites and enterprise facilities in rural areas. The study is written for whichever path the borrower takes, and it reads the program rules that come with SBA or USDA money.

    Exhibit 18. Financing paths and the rules that shape a data center study

    PathFitsKey limits and testsWhat the study must show
    SBA 7(a)Small hosting, colocation or managed services firms buying or building their own facility$5,000,000 maximum loan; $3,750,000 guaranty limit; 1.15 coverage, 1:1 global; projections must reach 1.15 within 2 years of funding or of the end of constructionOperating business, not a passive landlord; occupancy tests; business cash flow without project rental income [41][43]
    SBA 504The same borrowers financing real estate and long-lived equipmentDebenture limits of $5,000,000, or $5,500,000 per project for small manufacturers and for projects cutting energy use by at least 10%; borrower contribution of 15% for limited or special purpose property, 20% if also a new businessWhether the property is limited or special purpose; energy reduction if the higher limit is claimed [41][43]
    SBA with an Eligible Passive CompanyAn operating company that leases the facility from an affiliated real estate companyThe operating company must occupy the space under the occupancy tests; the passive company leases only to the operating company or companiesLease terms between the two companies; operating company cash flow [41][43]
    USDA Business and IndustryFacilities in rural areas that create or save jobsRural area outside cities over 50,000 and their urbanized areas; $25 million borrower limit; feasibility study required above $1,000,000 for a new entity or activityRural eligibility, market capacity test above $1 million and 50 new jobs, technical and management feasibility [44]
    Conventional bank construction and term loansEnterprise facilities, smaller colocation and edge projects with sponsors who can carry recourseLender's own coverage, loan-to-cost and pre-leasing termsPower schedule, lease-up, supply and coverage in downside cases
    Private credit, project and portfolio debtWholesale and hyperscale shells with long leasesTerms negotiated against the lease and the tenant's creditLease review, tenant credit, re-leasing case, utility contract alignment

    Source: 13 CFR Part 120 (revised as of January 1, 2026) [41]; SBA SOP 50 10 8.1 [43]; 7 CFR Part 5001 (revised as of January 1, 2026) [44]. Conventional and private terms vary by lender.

    SBA 7(a)

    SBA's 7(a) program fits an operating business that runs the data center itself. The first question is whether the borrower is an operating business at all. SBA excludes "passive businesses owned by developers and landlords that do not actively use or occupy the assets acquired or improved with the loan proceeds" [41]. A colocation operator that runs the facility, sells power, cooling, security and network services and employs the staff is a different business from a landlord that leases an empty powered shell. The study describes what the borrower actually does every day, who controls operations, and whether any management agreement gives a third party sole discretion, which SBA treats as making the applicant an ineligible passive business [43].

    The occupancy rules then apply. For new construction, the borrower must occupy at least 60% of the rentable property and may lease up to 20% long term; for an existing building, the borrower must occupy at least 51% and may lease up to 49% [41]. How those rules apply to a colocation operator, whose customers occupy cabinets inside space the operator controls and runs, is a judgment the lender makes on the facts; the study supplies the facts, including how the space is measured, who controls it and what the customer contracts say. More detail on the current procedures is on our page about the SOP 50 10 8.1 update and the SBA loan programs.

    Coverage must be at least 1.15 on a historical or projected basis and 1:1 globally [43]. For start-ups and construction projects, the projections must show 1.15 within 2 years of funding or of the end of construction [43]. Rental income from the project property may count in the global analysis but not in the repayment analysis [43].

    SBA 504

    The 504 debenture limit rises from $5,000,000 to $5,500,000 per project when the operating company's energy use falls by at least 10% [41]. A data center that replaces an older, less efficient facility may document such a reduction, and the study can supply the energy model.

    SBA asks whether the project property is limited or special purpose, defined as "a limited-market property with a unique physical design, special construction materials, or a layout that restricts its utility to the use for which it was built" [43]. SBA's list of examples does not name data centers, but it states that the list "is not intended to be all-inclusive" [43]. If the property is limited or special purpose, the borrower must contribute at least 15%, or 20% if the project also involves a new business [43]. The study gives the lender the evidence on design and alternative use so the lender can decide.

    USDA Business and Industry

    USDA's Business and Industry guarantee fits rural projects that create or save jobs. The site must be outside any city or town of more than 50,000 and its contiguous urbanized area [44]. The borrower limit is $25 million [44]. A study by an independent qualified consultant is required for guarantees above $1,000,000 to a new entity or new activity [44]. For B&I projects above $1 million that increase direct employment by more than 50, USDA applies a market capacity test against existing competitors [44]. Most data centers employ fewer people than their cost suggests, so the jobs test is often met easily, but the study should still show the job count and the market analysis. See USDA loan programs.

    Conventional and private capital

    Banks, private credit funds and large tenants finance most large projects, on terms negotiated rather than published. A construction lender wants the power schedule, pre-leasing and cost to complete; a term lender wants stabilized coverage and the re-leasing case. See conventional loan programs.

    What downside cases should the study run?

    At least one for each assumption that can fail. A data center's cash flow is unusually sensitive to dates, because rent often starts only when the utility energizes capacity, and to fixed power commitments, because minimum bills run whether or not tenants arrive. The study runs each case through the same model as the base case and reports coverage and any equity or reserve needed to hold it.

    Exhibit 19. Downside cases for a data center study

    CaseWhat changesWhy it matters
    Energization delayUtility capacity arrives 6, 12 or 18 months lateRent start slips while interest and some fixed costs continue
    Slower lease-upAbsorption at half the base caseMinimum bills and staffing costs run ahead of revenue
    PUE above designPUE 0.1 to 0.3 higher than design in early yearsEnergy cost rises in proportion when power is not passed through
    Power price increaseDelivered price up by a stated amountSame effect as PUE when the operator carries power
    Tenant exitLargest tenant leaves at its earliest rightRe-leasing downtime, cost and rent for a specialized building
    Construction cost overrunElectrical and cooling plant costs above budgetEquity need and loan-to-cost limits
    Utility minimum bill exposureMinimum bill owed on capacity not yet leasedFixed cost not covered by rent during ramp

    Source: FSC method; minimum bill and term examples from the Kansas Corporation Commission and the Missouri Public Service Commission [19][21]. Case sizes are model inputs, not market figures.

    The calculator's worked cases show how quickly coverage moves. In its default case, coverage is 1.22. With power fully passed through to tenants, coverage rises to 2.07; with a PUE of 1.60 and a higher power price the operator absorbs, it falls to 0.50; and with only 5 MW leased instead of 8, it falls to 0.64. Those results come from illustrative inputs, but the pattern holds for real projects: who pays for power and how fast capacity leases matter more than almost anything else in the model.

    What must a data center feasibility study contain?

    It must contain enough evidence for a credit officer who has never seen the site to follow every number to its source and to see the cash flow under stress. A study for a data center usually includes the parts in Exhibit 20.

    Exhibit 20. Contents of a data center feasibility study

    PartWhat it covers
    Executive summary and conclusionFeasible as proposed, feasible with conditions, or not feasible as proposed; the conditions in plain words
    Project descriptionCapacity in critical MW by phase, building, electrical and cooling design, design PUE, network, schedule
    Power analysisUtility agreements, tariff, minimum bill, collateral, exit terms, upgrades, queue position, backup power and permits
    Market and demand analysisCompetitive area, operating and planned supply by power status, absorption in kW, rents, tenant prospects
    Site and permitsZoning, approvals still needed, fiber routes, water, environmental condition, generator air permits
    Tenant and lease reviewLease terms, tenant credit, termination and contraction rights, alignment with the utility contract
    Incentives and taxesState sales and use tax exemptions, qualification path, local property tax agreements
    Development budgetLand, building, electrical and mechanical plant, network, soft costs, interest, reserves, collateral
    Operating projectionRevenue by product, power cost, staffing, maintenance, insurance, taxes, equipment replacement
    Financing and coverageProgram rules, sources and uses, debt service, coverage in base and downside cases
    Sources and evidenceEvery figure linked to its document, with the date of each source

    Source: FSC method; SBA SOP 50 10 8.1 and 7 CFR 5001 for the program content noted in each part [43][44].

    USDA's rule describes the study as an evaluation of "economic, market, technical, financial, and management feasibility" [44]. For a data center, "technical" means the power and cooling plan as much as the building, and "management" means the team's record of running a facility around the clock.

    How does the engagement run, and what comes after closing?

    The engagement follows the order of risk: power first, then demand, then the rest. Scope depends on the project type, the capital source and how much of the utility and leasing work is already documented. This page describes scope and deliverables only; the proposal sets out the rest.

    1. Scoping. Confirm the capital source, the lender's requirements and the documents available: utility agreements, leases or letters of intent, design, budget and permits.
    2. Power review. Read the utility documents and tariff; list what is committed, pending or open to change.
    3. Market and site work. Survey competing supply, network routes, the site and remaining approvals.
    4. Model. Build the budget, the operating projection and the coverage tests, including downside cases.
    5. Draft, review and final. Correct factual errors raised in review without changing independent conclusions, then deliver the signed study.

    After closing, some lenders ask for periodic monitoring: construction progress against the power schedule, leasing against the projection, and actual PUE and power cost against the model. The same evidence base supports that work. The study is signed by Sarrah Allen, MAI. More about the firm is on the about page, and other property types are on the asset classes page.

    How do the states compare on data center fundamentals?

    Exhibit 21 brings the main public series together for every state. It shows the industry's establishments and employees from County Business Patterns, average commercial and industrial electricity prices, the change in commercial retail sales from the first eight months of 2025 to the same months of 2026, and total net summer generating capacity. Read it as a first screen. A site's power terms come from its utility, not from a state average.

    Exhibit 21. Data center fundamentals by state

    State518210 establishments518210 employeesCommercial price, YTD Aug 2026 (cents/kWh)Industrial price, YTD Aug 2026 (cents/kWh)Commercial sales change, YTD 2026 vs 2025Net summer capacity, Aug 2026 (MW)
    Alabama1523,58814.837.96+1.8%31,326.4
    Alaska331,07423.0423.90+4.2%2,857.1
    Arizona33714,60712.287.94+14.2%41,591.1
    Arkansas1296,13111.556.96-0.1%17,093.1
    California2,698123,85926.9621.11-0.8%104,232.7
    Colorado55417,68913.379.64+3.0%21,780.6
    Connecticut2114,96221.7518.16+1.0%10,129.6
    Delaware2061,74313.9911.56-1.2%2,930.6
    District of Columbia1193,49423.7020.47-2.1%67.2
    Florida1,26630,38511.789.20+2.1%75,067.4
    Georgia56726,23012.018.67+6.6%40,705.6
    Hawaii5952842.4337.83-2.7%3,474.4
    Idaho1082,0029.758.37+2.9%6,566.6
    Illinois62721,93414.0510.42-1.6%48,735.7
    Indiana2584,97713.849.17+13.8%31,912.6
    Iowa1263,90011.667.66-0.4%23,774.5
    Kansas1463,67911.778.33+3.7%20,133.6
    Kentucky4416,97112.647.49-1.1%19,292.0
    Louisiana1302,88411.766.58-0.2%25,864.3
    Maine641,84022.8315.62-2.4%5,956.5
    Maryland44813,63117.1614.87+0.1%12,437.9
    Massachusetts51027,90524.6619.94-0.0%12,758.9
    Michigan45510,19815.809.29+0.6%34,150.1
    Minnesota29115,63312.709.78+4.6%18,701.4
    Mississippi741,62114.007.65+0.8%16,539.4
    Missouri2657,38911.178.78+3.4%21,839.9
    Montana5870112.896.99-0.2%7,255.5
    Nebraska1246,3139.068.62+18.4%11,498.5
    Nevada2043,4199.368.69+7.0%17,887.5
    New Hampshire943,41821.4018.07+1.9%4,330.8
    New Jersey59518,63217.9015.31+0.2%16,762.4
    New Mexico7794310.965.19-1.2%17,545.2
    New York1,01339,73022.9310.33-0.3%41,557.0
    North Carolina45017,24110.617.95+2.2%36,755.0
    North Dakota322347.728.18-0.4%10,672.0
    Ohio63314,69213.6110.23+14.4%33,157.3
    Oklahoma1613,2969.356.89+5.1%34,422.3
    Oregon2316,70610.598.38-8.1%18,483.2
    Pennsylvania93719,44313.9010.82-0.2%49,446.2
    Rhode Island4648823.6821.57+0.2%2,418.3
    South Carolina1863,72711.867.86+5.0%25,148.5
    South Dakota5342511.689.45-0.7%7,248.6
    Tennessee2488,80213.576.84+1.1%21,162.6
    Texas1,41256,2908.606.77+8.3%194,097.3
    Utah2689,23910.388.58+7.7%11,578.4
    Vermont412,29420.8712.90-0.1%855.7
    Virginia64133,40411.2010.07+2.6%29,862.6
    Washington47614,48511.867.17+2.8%31,106.9
    West Virginia4546111.648.26+3.8%15,313.1
    Wisconsin1865,99813.739.60+2.3%18,499.6
    Wyoming592929.828.78+6.8%11,825.3
    United States18,544629,52714.049.09+3.3%1,318,809.0

    Source: U.S. Census Bureau, County Business Patterns 2023, NAICS 518210 [2][3]; U.S. Energy Information Administration, Electric Power Monthly, Tables 5.4.B, 5.6.B and 6.2.A, data through August 2026 [4][5][6][7]. Changes calculated by FSC. CBP counts for small states carry Census noise flags; employment is mid-March 2023.

    The lowest-price states are not all the states with the most data processing employment; price is one input among network, workforce and utility capacity [3][4]. Commercial sales grew fastest in Nebraska, Ohio, Arizona and Indiana, each above 13% [5], and the largest capacity additions were in Texas, Arizona and New Mexico [6].

    Download the evidence behind this page's exhibits (CSV, 821 data points with sources)

    Data center engagements

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    Building or financing a data center?

    A 30-minute scoping call, then a fixed-fee engagement letter within 24 hours naming the capital sources the study must satisfy and the analyst and reviewer who will sign it.

    Frequently Asked Questions

    What does a data center feasibility study conclude?
    It concludes that the project is feasible as proposed, feasible with stated conditions, or not feasible as proposed. Conditions for a data center are usually tied to power, such as a signed utility agreement for a stated capacity and date, or to leasing, such as a minimum level of signed capacity before construction starts.
    Why is power the first question in a data center study?
    Because rent and operations cannot start until the utility energizes capacity, and large-load tariffs now attach minimum bills, collateral and long terms to that capacity. Kansas, for example, requires a minimum bill of 80% of contract demand for loads of 75 MW or more [19].
    How much electricity do U.S. data centers use?
    About 176 TWh in 2023, or 4.4% of U.S. electricity, according to the Lawrence Berkeley National Laboratory report released by the Department of Energy [8][9]. The laboratory's 2028 scenarios run from about 325 to 580 TWh [9].
    What is PUE and what value should a study assume?
    PUE is total facility power divided by IT equipment power. The national average was about 1.4 in 2023 by the laboratory's estimate [9]. A study should use the project's design PUE, then test a worse value, because the laboratory notes that systems rarely operate exactly as designed [9].
    How fast is data center construction growing?
    Private data center construction ran at a seasonally adjusted annual rate of $96,462 million in September 2026 (preliminary), up 90.3% from $50,700 million in September 2025 [1].
    What is a large-load tariff?
    It is a utility rate schedule or rule for customers above a size threshold, such as 75 MW in Kansas or more than 100 MW for Georgia Power, with longer contracts, minimum bills and collateral [18][19]. Its purpose is to keep other customers from paying for capacity built for one very large user.
    How long are utility contracts under large-load tariffs?
    In Kansas and Missouri, a minimum of 12 years plus an optional ramp of up to 5 years, for up to 17 years in total [19][21]. Georgia's rule allows contracts to move from 5-year to 15-year terms [18].
    What is the Ratepayer Protection Pledge?
    It is a voluntary commitment recorded in Proclamation 11014; on March 4, 2026, seven technology companies accepted its terms, including paying for new power delivery upgrades for their data centers [11]. It binds the companies that signed it and does not change utility tariffs.
    What is FERC doing about co-location and large loads?
    FERC opened an investigation of the PJM tariff's treatment of co-located load on February 20, 2025 (EL25-49), and a large-load interconnection rulemaking docket (RM26-4) began with the Secretary of Energy's proposal of October 23, 2025 [12][15]. FERC's August 2026 agenda listed the next action in RM26-4 as undetermined [15].
    Does Executive Order 14318 apply to every data center?
    No. It defines a Data Center Project as one needing more than 100 MW of new load for artificial intelligence workloads, and its qualifying tests include $500 million of committed capital spending or more than 100 MW of incremental load [10]. Smaller projects benefit mainly from the environmental review and brownfield measures it calls for.
    Can an SBA loan finance a data center?
    Yes, if the borrower is an eligible small operating business and the project meets the program rules. SBA excludes passive businesses owned by developers and landlords, applies occupancy tests and caps a 7(a) loan at $5,000,000 [41].
    What is the SBA size standard for a data center business?
    $40.0 million in average annual receipts for NAICS 518210, computing infrastructure providers, data processing, web hosting and related services [42].
    Is a data center a special purpose property for SBA 504?
    SBA's list of limited or special purpose properties does not name data centers, but the list is not all-inclusive, and SBA can decide that other properties meet the definition [43]. If the lender treats the property as special purpose, the borrower contribution rises to at least 15%, or 20% with a new business [43].
    Can USDA guarantee a loan for a rural data center?
    It can if the project is in a rural area outside cities over 50,000 and their urbanized areas, the borrower is eligible and the loan fits the B&I rules, including the $25 million borrower limit [44]. A feasibility study is required for guarantees above $1,000,000 to a new entity or new activity [44].
    How does the study handle a single-tenant hyperscale lease?
    As a credit exposure. It reads the lease term, rent start conditions, termination and contraction rights and any guarantee, then tests coverage with the tenant paying and with the tenant gone at its earliest exit.
    What demand evidence matters for a colocation building?
    Capacity leased and sought in kilowatts, the rents tenants pay per kilowatt per month, competing supply sorted by power status, and the subject's likely share of absorption. Square-foot rents from office or industrial markets do not measure data center demand.
    How does the study treat an edge data center?
    It focuses on network routes, latency needs, the local business base and any committed anchor customer. County Business Patterns counts for NAICS 518210 help gauge whether a local hosting market exists [3].
    Which backup generator rules apply?
    Federal rules for stationary engines allow emergency engines unlimited use in emergencies, up to 100 hours a year for maintenance and testing, and up to 50 of those hours for limited non-emergency use [35][39]. Running beyond those limits can cost an engine its emergency status.
    Can backup generators be used for demand response or peak shaving?
    Generally not as emergency engines. The 50 non-emergency hours cannot be used for peak shaving or non-emergency demand response, except for limited dispatch by the local balancing authority or distribution operator to avoid local outages under stated conditions [35].
    Which states exempt data center equipment from sales tax?
    Many do, with conditions. Virginia, Nevada, Minnesota, Missouri, North Carolina, Iowa, Georgia and Arizona all have statutory programs tied to investment and, in most cases, job and wage tests, as summarized in Exhibit 16 [23][24][25][26][27][29][31][32].
    What investment does Virginia require for its data center exemption?
    At least $150 million of new capital investment and 50 new jobs at 1.5 times the local prevailing wage, reduced to $70 million and 10 jobs in distressed localities; the exemption runs through June 30, 2035, with extensions for much larger investments [23].
    How does water use affect a data center study?
    Cooling design sets water use as well as PUE. Direct water use by U.S. data centers was about 66 billion liters in 2023 by the laboratory's estimate, with hyperscale and colocation facilities using 84% [9]. The study checks supply, charges and local limits for the chosen design.
    What does the 50-state panel show?
    It lists, for every state, NAICS 518210 establishments and employees, average commercial and industrial electricity prices through August 2026, the change in commercial electricity sales and total generating capacity [2][3][4][5][6]. It is a screen, not a site analysis.
    How do depreciation rules treat data center assets?
    The building is 39-year property, computers are 5-year property, and Public Law 119-21 made the 100 percent special allowance permanent for property acquired after January 19, 2025 [45][46]. These rules affect after-tax cash flow rather than most coverage tests.
    What does the calculator on this page test?
    It turns leased megawatts, average IT draw, PUE and power price into annual energy cost, then adds rent per kilowatt per month and the share of energy cost recovered from tenants to reach net operating income and debt service coverage. Its inputs are illustrative, and its result is not a feasibility conclusion.

    Sources

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    2. 2.U.S. Census Bureau. "County Business Patterns 2023, U.S. file (cbp23us)." https://www2.census.gov/programs-surveys/cbp/datasets/2023/cbp23us.zip (accessed 2026-11-11)
    3. 3.U.S. Census Bureau. "County Business Patterns 2023, state file (cbp23st)." https://www2.census.gov/programs-surveys/cbp/datasets/2023/cbp23st.zip (accessed 2026-11-11)
    4. 4.U.S. Energy Information Administration. "Electric Power Monthly, Table 5.6.B, Average Price of Electricity to Ultimate Customers by End-Use Sector, by State, Year-to-Date." https://www.eia.gov/electricity/monthly/xls/table_5_06_b.xlsx (accessed 2026-11-11)
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    6. 6.U.S. Energy Information Administration. "Electric Power Monthly, Table 6.2.A, Net Summer Capacity of Utility Scale Units by Technology and by State." https://www.eia.gov/electricity/monthly/xls/table_6_02_a.xlsx (accessed 2026-11-11)
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    10. 10.Executive Office of the President. "Executive Order 14318, Accelerating Federal Permitting of Data Center Infrastructure, 90 FR 35385." https://www.federalregister.gov/documents/full_text/text/2025/07/28/2025-14212.txt (accessed 2026-11-11)
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    25. 25.Minnesota Office of the Revisor of Statutes. "Minnesota Statutes 297A.68, Business Exemptions, subdivision 42, Data centers." https://www.revisor.mn.gov/statutes/cite/297A.68 (accessed 2026-11-11)
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