Part 9 of 13 in Thirteen Records. The long article, Data Centers Don’t Have an Environmental Record. They Have Thirteen of Them., rates thirteen kinds of environmental complaint against data centers. This series takes them one at a time.
I work at a local ISP in Northern Illinois and co-founded FD-IX, an internet exchange. I have no customer, vendor, or interconnection relationship with any facility or developer named here and no financial position in any of them beyond broad-market index funds. My industry grows with infrastructure investment in a general way, which is an indirect interest; the full disclosure is at the top of the complete article.
Data centers in Northern Illinois go on farmland. Corn and soybeans are the prior use on nearly every parcel in the Eldamain corridor, and the conversion is permanent. That is the one environmental claim in this series that is true everywhere, and it is also the one that is least about data centers. The decision in front of a council is whether to rezone farmland for industry at all, and that is a judgment about land, not a finding about the building.
This post rates two land claims. The first, that data centers are taking farmland, holds. The second, that a data center is the worst thing you could put on the parcel, does not survive comparison with the warehouse campus that is usually the alternative, though no controlled study has measured the two side by side. It ends with what Project Cardinal’s approval actually requires on the land, and with the end-of-life condition that no data center approval I reviewed contains and that Illinois already requires of solar and wind.
How the ratings work. Each complaint below is stated the way it usually arrives at a hearing and rated on the scale the full article uses. Systemic: documented at compliant facilities across multiple geographies. Regional: real, but only under specific geographic or operational conditions. Isolated: documented at one or few facilities due to misconduct or atypical design. Exaggerated: the concern is real but the figures are permit ceilings or worst cases, not operating norms. Selective: a legitimate concern applied only to data centers, not to comparable land uses. Misattributed: the harm is real but the source, geography, or cause is wrong. Contested: a plausible mechanism exists but causal documentation at compliant facilities does not. Fabricated: no credible evidentiary basis exists. Where I say I found no record of something, that means a search of public sources through October 2026, not paid databases or records requests.
Land and Habitat
Claim: Data centers are taking our farmland. Tier: Systemic.
True, and permanent. Data centers in Northern Illinois are typically sited on agricultural land, with corn and soybeans the dominant prior use. The decision in front of most councils is therefore whether to rezone farmland for industry at all, and that is a values question about land, not a finding about data centers. Where the alternative is continued agriculture, the questions that matter are prime farmland loss, drainage district and field tile disruption, impervious cover, detention basin maintenance, and post-construction stormwater performance. Those deserve their own treatment and do not get it here.
Claim: A data center is the worst thing you could put on this land. Tier: Selective.
Where a parcel is already industrial or certain to be, the comparison is another industrial use, and the record does not support ranking data centers worst. A warehouse distribution campus generates its own footprint: heavy truck traffic, disproportionately at night, diesel particulate at loading docks, and refrigeration noise. [33a] No controlled study has measured the two uses against each other on matched parcels. On known characteristics they differ in kind: a data center’s operating impacts are continuous and mechanical, a warehouse’s vehicular and peak-driven, and which a neighbor would rather live beside depends on what that neighbor is sensitive to. A council weighing a parcel can fairly ask what use or site would be acceptable. If the answer is none, the objection is to the building or to a constraint every local site shares, such as transmission, water, or residential proximity, and each is legitimate argued as what it is.
The Cardinal approval shows what conditions on the land can look like. The PUD agreement approved November 10, 2025 carries a 100-foot landscape buffer on all four road frontages with a 12-foot berm facing homes and 8 feet elsewhere, a 500-foot separation from any home or business occupied on the approval date, and a 78-foot height limit including rooftop equipment. [11x] Shaw Local’s account adds 4,900 new trees and setbacks of 625 and 1,200 feet from the two nearest subdivisions, from the plan exhibits. [11m] The record I located has no stormwater performance data and no measure of net habitat outcome.
What to ask for. Treat the farmland question as the values question it is and argue it as one: prime farmland loss, drainage district and field tile disruption, impervious cover, detention basin maintenance, and post-construction stormwater performance are the questions that matter where the alternative is continued agriculture, and they deserve their own study. Where the parcel is going industrial regardless, compare the uses honestly. A warehouse campus brings night truck traffic, dock diesel, and refrigeration noise; a data center brings continuous mechanical load. [33a]
Require an end-of-life plan and the money to execute it. Illinois already requires a decommissioning plan and financial assurance as a condition of county siting approval for commercial solar and wind, with the plan filed at application and the security posted before the building permit. [42] Data centers are permitted with no equivalent in the approvals I reviewed. The buildings are refit on multi-year hardware cycles, and whether a campus built for one generation of hardware suits the next is a question no approval asked. Require a decommissioning plan covering demolition, foundation and slab removal, restoration of pervious surface, and disposal of batteries, dielectric fluids, and fire suppression agents, with financial assurance sized to that plan and adjusted periodically. This is the condition with the longest tail and the one least likely to be raised at the hearing where it matters.
What nobody knows. I found no controlled comparison of data center thermal, noise, or air quality impacts against comparably sized warehouses or plants on matched parcels, and none against continued agriculture where the decision is whether to rezone at all.
This is part 9 of 13 in Thirteen Records, a series that takes the long article Data Centers Don’t Have an Environmental Record. They Have Thirteen of Them. one topic at a time. Previous: thermal effects. Next: light pollution and wildlife, a real effect of any campus lit through the night.
Cover photo: U.S. Forest Service / Wikimedia Commons, public domain
Citations
[11m] Joey Weslo, Shaw Local News Network (Kendall County Now), “Yorkville OKs ‘larger than Central Park in New York’ data center campus,” November 14, 2025. Unanimous approval of the Project Cardinal PUD on November 10, 2025: 4,900 new trees; a landscaped 12-foot berm near residential properties narrowing to eight feet elsewhere; 625-foot setback from Bristol Bay and 1,200 feet from Equestrian Estates; 78-foot height limit including rooftop equipment; generator testing only during daytime; city monitoring of light pollution; phased construction under a 20-year PUD. https://www.shawlocal.com/kendall-county-now/2025/11/11/yorkville-oks-1037-acre-project-cardinal-data-center/ (archived: https://web.archive.org/web/20260415165443/https://www.shawlocal.com/kendall-county-now/2025/11/11/yorkville-oks-1037-acre-project-cardinal-data-center/)
[11x] United City of Yorkville, Ordinance No. 2025-77, approving the Planned Unit Development Agreement for Project Cardinal, passed November 10, 2025 (7-0), signed by the mayor November 13, 2025, published November 14, 2025; city-posted executed copy, mayor’s signature and clerk’s attestation dated November 13, 2025, Pioneer Development signature and date lines blank. Section 2.1: vesting applies “Upon commencement of the Project within three (3) years of the Effective Date.” Section 2.2: “Section 10-4-10 of the UDO is reserved for additional regulations applicable to Energy Industrial Uses. No new or amended standards, code provisions, or special regulations for Energy Industrial Uses shall apply to the Subject Property during the twenty (20) year vested term from the Effective Date of this Agreement, unless Developer agrees in writing or to the extent required by state or federal law.” No reference to Ordinance 2025-53. Section 2.14: “seventy-eight (78) feet, inclusive of any rooftop mechanical equipment or appurtenances.” Section 3.5: water obligations “addressed exclusively in the Utility Agreement.” https://www.yorkville.il.us/DocumentCenter/View/13587/Ordinance-2025-77—record?bidId= (archived: https://web.archive.org/web/20261025151237/https://www.yorkville.il.us/DocumentCenter/View/13587/Ordinance-2025-77—record?bidId=). Annexation agreement, Ordinance No. 2025-78: https://www.yorkville.il.us/DocumentCenter/View/13588/Ordinance-2025-78—record?bidId= (archived: https://web.archive.org/web/20261025151421/https://www.yorkville.il.us/DocumentCenter/View/13588/Ordinance-2025-78—record?bidId=). Packet version: City Council Packet, November 10, 2025 (ArchiveCenter Item 6499), Planned Unit Development Agreement between the United City of Yorkville and Pioneer Development, LLC (Project Cardinal), packet pp. 272 to 290. Section 2.1: entitlements “fully vested and protected from amendments and changes to City ordinances, codes, or regulations for a period of twenty (20) years from the Effective Date.” Section 2.2: “No new or amended standards, code provisions, or special regulations for Energy Industrial Uses shall apply to the Subject Property during the twenty (20) year vested term from the Effective Date of this Agreement, unless Developer agrees in writing or to the extent required by state or federal law.” Section 2.3: approximately ten-year build-out; Phasing Plan “advisory only and non-binding.” Section 2.4: “All data center buildings shall be at least five hundred feet (500′) from the nearest residential or commercial structure outside the boundaries of the Subject Property,” measured “from existing, occupied, residential or commercial buildings as of the date of PUD approval.” Section 2.10: 100-foot Transition Zone Type D buffer with a 12-foot berm facing residential properties and 8 feet elsewhere; “No additional berms or landscape requirements shall be imposed unless Developer agrees in writing.” Section 2.11: “the most appropriate location for Mechanical Equipment is on the rooftops; therefore, whenever practical, mechanical equipment shall be placed on the rooftops”; project subject to the City Noise Ordinance “as it existed when the PUD application was approved by the City Council.” Section 2.14: 78-foot maximum height including rooftop equipment. Section 2.17: “all primary power used for the data center campus on the Subject Property will be delivered from the Commonwealth Edison power grid” unless the City Council approves otherwise. Section 3.4: continuous noise monitoring devices at the onset of each construction phase, a preliminary report within 60 days after each building is operational, devices maintained for the life of the project. Section 3.11: operational testing of generators “during the hours of 11:00 a.m. to 5:00 p.m., Monday through Friday, and not on any Holidays.” https://www.yorkville.il.us/ArchiveCenter/ViewFile/Item/6499 (archived: https://web.archive.org/web/20261025154939/https://www.yorkville.il.us/ArchiveCenter/ViewFile/Item/6499)
[33a] LOCUS (locusdata.io), “Impacts of warehouses and ports on truck traffic,” analysis of Arizona truck traffic data documenting disproportionate nighttime truck activity around logistics facilities. [Data-vendor blog, not peer reviewed.] https://locusdata.io/blog/impacts-of-warehouses-and-ports-on-truck-traffic (archived: https://web.archive.org/web/20260416171405/https://locusdata.io/blog/impacts-of-warehouses-and-ports-on-truck-traffic)
[42] 55 ILCS 5/5-12020, Counties Code, commercial wind energy facilities and commercial solar energy facilities: county siting standards including a deconstruction (decommissioning) plan and financial assurance, implemented through the Agricultural Impact Mitigation Agreement with the Illinois Department of Agriculture. Accessible county implementation: Macon County Code, Chapter 156, Commercial Solar Energy Facility Siting: applicant “must submit a decommissioning plan with cost estimation to the county as part of the siting application” and “post the required financial assurances for the benefit of the county” before a building permit; “The decommissioning agreement and financial assurances shall comply with 55 ILCS 5/5-12020.” https://codelibrary.amlegal.com/codes/maconcounty/latest/maconcounty_il/0-0-0-8916 (archived: https://archive.org/details/macon-county-code-chapter-156-2026-10-25, the page text as displayed October 25, 2026, uploaded because the Wayback Machine cannot capture the code library’s JavaScript page)