The EHS Gaps the Data Center Industry Isn’t Talking About
Article 1 of 4 in the series: The Full Lifecycle of EHS in Data Center Development
By Julie Wojnowski, Principal & Practice Lead, ESG & Sustainability | Citadel EHS
If you had told me years ago — as a first-generation college graduate studying nursing systems and English — that I would be writing about data center cooling systems, generator emissions permitting, and water use effectiveness metrics, I might have paused.
But my career has always centered on one principle: how systems impact people. And right now, few systems are reshaping American communities as rapidly as data center development.
I see it every day in the Carolinas, where I live and work.
What I’m Seeing in My Own Backyard: Data Center Growth in the Carolinas
In York County, just outside Charlotte, QTS continues expanding its data center campus — reinforcing the Southeast’s role in hyperscale and AI infrastructure. In Spartanburg County, local officials recently approved the second reading of a tax incentive package for TigerDC’s proposed $3 billion AI-focused campus, Project Spero, with the first phase expected to deliver 100MW and incorporate closed-loop cooling.
These aren’t abstractions for me. These are projects unfolding in the communities where I raise my family, where I volunteer, where I serve on boards. The land use decisions, the water demand, the construction activity, the air quality implications — I experience these as a neighbor, not just a consultant.
That proximity is also what makes me proud of what South Carolina is doing legislatively. The recently introduced Data Center Development Act (S.867) and Data Center Siting Act (S.902) go beyond tax incentives. They establish a structured governance framework that includes formal siting certification, infrastructure adequacy assessments, environmental impact review, measurable WUE-based water efficiency standards, noise and vibration mitigation requirements, decommissioning plans, and ongoing compliance reporting. The legislation also encourages development on brownfield and previously industrial sites — which introduces its own set of EHS considerations, from Phase I/II environmental assessments to vapor intrusion evaluation and remediation oversight.
This isn’t about slowing growth. It’s about creating predictability, protecting ratepayers, conserving water resources, and aligning infrastructure expansion with long-term environmental stewardship. I hope South Carolina’s approach sets a precedent — not just for other states, but for an industry that is still figuring out how to govern its own explosive growth responsibly.
As a board member at the Green Building Initiative, I’m directly involved in GBI’s Advancing Sustainable Data Centers program — and I’ll be in Dallas on May 5–6 representing GBI at their Advancing Sustainable Data Centers Seminar at the Dallas Arboretum and Botanical Garden, engaging with designers, owners, and operators on exactly these sustainability and resilience challenges. I was also recently elected to the board of CleanAIRE NC, a clean air and environmental justice organization in the Carolinas — a role that deepens my commitment to understanding how infrastructure development impacts the communities where we live and work.
It’s this combination — watching data centers arrive in my community, working in ESG and sustainability, and engaging with governance and environmental justice at the board level — that led me to Dallas last week.
Why I Attended a Data Center Cooling Conference
In February, I spent two days at the Advancing Data Center Cooling Innovation conference — a forum dedicated to the evolving role of mechanical engineering in next-generation data centers. The speakers were from Microsoft, AWS, Equinix, NTT Global Data Centers, JLL, Arcadis, and a dozen other firms at the forefront of this infrastructure shift. The conversations about liquid cooling transitions, AI-driven load growth, water use effectiveness, and high-density rack design were some of the most sophisticated I’ve heard in any sector.
I went because the engineering decisions being made in rooms like that one — decisions about cooling systems, water consumption, power density, and equipment layout — have direct environmental, health, and safety consequences. And I wanted to understand those decisions from the engineers making them.
What I found was extraordinary technical depth — and a significant gap. Data center EHS — the integration of environmental permitting, worker safety, and long-term compliance into the infrastructure decisions being made right now — wasn’t on the agenda.
That gap is exactly why I was there.
The Sessions That Stood Out — and Their EHS Implications
I want to highlight a few speakers who made a particular impression — not because they addressed EHS directly, but because their work has profound EHS implications that deserve attention.
Duane Warren, Engineering Director at JLL, was involved in multiple sessions, and his contributions consistently stood out. What I appreciated most was his candor. He didn’t just present theory — he told stories from the field about managing contractors, navigating expectations, and dealing with the realities of building and operating these facilities. That kind of honesty is rare in a conference setting, and it’s exactly the perspective that bridges the gap between design intent and operational reality.
Nissim Gore-Datar and Rajat Bhagat from Arcadis delivered one of the sessions I found most valuable — on balancing water use and energy efficiency in next-generation data centers. They walked through how geographic and climatic constraints shape cooling design decisions, how operators can collaborate with municipalities to unlock sustainable water sources like non-potable water and wastewater reuse, and how WUE needs to sit alongside PUE as a core mechanical design KPI. I learned an enormous amount about water usage in this session — and my conversations with Rajat throughout the conference deepened that understanding further. From an EHS perspective, this session was a reminder that every cooling system choice carries water permitting, discharge compliance, and community impact implications that need to be addressed well before construction begins.
Hunter Bercow, Mechanical Engineer at NTT Global Data Centers, facilitated a panel on strengthening stakeholder communication between design and operations teams. His insights were grounded in having worked across the full lifecycle of data center projects — from design through commissioning through operations. He brought a practitioner’s understanding of where things break down. If I were staffing a data center project, I’d want someone with that breadth of experience on the team.
Noah Poe, VP of Engineering at Menlo Equities, presented on bridging electrical and mechanical strategies to control rapid AI load swings — co-designing generator, UPS, and cooling system responses so that electrical and mechanical systems operate in sync rather than in silos. It was a deeply technical topic, and he delivered it with remarkable efficiency and clarity. No wasted words, no wasted slides. Just a thorough, straightforward presentation of complex content.
Kevin Shipley, Senior Mechanical Engineer at Microsoft, presented a case study on improving mechanical equipment layout and planning to maximize space utilization. It was fascinating. He showcased real solutions that could save considerable energy and dollars — the kind of practical engineering work that makes you appreciate the discipline behind these facilities.
Each of these sessions reinforced something I’ve been thinking about for a long time: the engineering decisions being made in these rooms cascade into environmental permitting requirements, worker safety protocols, and long-term compliance obligations that most teams don’t encounter until it’s expensive to address.
The EHS Gaps in Data Center Design
The conference theme was “Redefining the Thermal, Water, & Mechanical Systems for the Next Generation of Data Centers.” That’s an accurate description of what’s happening. But redefining those systems also means redefining the EHS landscape around them.
The transition from air cooling to liquid cooling doesn’t just change the thermal profile of a facility. It introduces new coolant chemicals that require hazardous materials management. It creates CDU maintenance environments that may qualify as confined spaces. It changes the piping system hazard profile in ways that traditional data center safety programs weren’t designed to address. (I’ll explore this further in Article 2 of this series, focused on construction and commissioning safety.)
Water use effectiveness isn’t just a mechanical design KPI. When an engineer chooses between air-cooled, adiabatic, and hybrid adiabatic systems, that choice directly determines water withdrawal permit requirements, discharge permitting obligations, and compliance with emerging state-level water efficiency standards — like the WUE benchmarks embedded in South Carolina’s new legislation. Nissim and Rajat’s session on collaborating with municipalities to unlock sustainable water sources was compelling engineering. But from where I sit, it’s also a compliance and community relations conversation that needs EHS involvement from day one. (Article 3 in this series will take a deep dive into environmental permitting and water stewardship for data centers.)
Scaling generator fleets to support AI-ready power densities isn’t just an electrical engineering challenge. A large data center campus with 50 to 200 diesel backup generators represents an emission source comparable to a small power plant. As campuses scale, many are crossing the threshold from minor source to major source classification under the Clean Air Act — triggering Title V permitting and significantly more complex compliance obligations. (Article 4 will cover generator emissions at scale, along with PFAS and battery storage safety — the hidden liabilities most operators haven’t addressed.)
The commissioning phase — the transition from construction to live systems — was referenced throughout the conference, particularly in discussions about bridging design intent and operational reality. But the safety implications of commissioning are profound. You’re energizing massive electrical systems while construction may still be active in adjacent areas. Arc flash hazard analysis, lockout/tagout coordination between construction and commissioning zones, and phase-specific safety plans are not optional considerations. They’re life-safety requirements. (More on this in Article 2.)
These aren’t peripheral concerns. They’re embedded in the decisions being made in every session I attended.
Where EHS Strategy Belongs in Data Center Development
Data center development is not simply about power density or cooling efficiency. It’s about building resilient infrastructure that protects people, communities, and natural resources.
At Citadel EHS, we support data center projects from site selection through operations — integrating environmental engineering, industrial hygiene, safety consulting, permitting strategy, and sustainability planning. That includes Phase I and Phase II environmental assessments, brownfield redevelopment strategy, stormwater and air emissions permitting, construction safety and exposure monitoring, commissioning safety planning, and long-term environmental compliance and ESG reporting.
But this article isn’t a capabilities pitch. It’s a call to the data center industry to bring EHS into the conversation earlier and more intentionally.
The engineers I listened to in Dallas are doing extraordinary work. The cooling systems they’re designing will shape infrastructure for decades. But those systems don’t exist in a regulatory vacuum, and the people who build, commission, and operate them deserve safety programs as sophisticated as the technology itself.
Whether you’re a developer evaluating a site, a GC managing a build, or an operator running a facility — the EHS questions are coming. Legislation like South Carolina’s Data Center Development Act signals that governance is catching up to growth. The firms and teams that integrate environmental, health, and safety strategy now, rather than bolting it on later, will be the ones positioned for the long term.
What’s Next in This Series
This is the first article in a four-part series exploring the full lifecycle of EHS in data center development:
Article 2 — Construction and commissioning safety: the highest-risk phases that most EHS programs don’t specifically address — including how the liquid cooling transition changes the safety profile
Article 3 — Environmental permitting and water stewardship: how engineering decisions cascade into regulatory obligations, and what emerging state frameworks mean for compliance
Article 4 — The hidden liabilities: PFAS in fire suppression, battery storage safety, and what happens when your generator campus crosses the Title V threshold
Data centers power the digital economy. How we develop them will define our environmental legacy.
Julie Wojnowski is Principal and Practice Lead for ESG & Sustainability at Citadel EHS. She serves on the board of the Green Building Initiative and was recently elected to the board of CleanAIRE NC. She is actively involved in GBI’s Advancing Sustainable Data Centers program and will be representing GBI at their May 5–6 seminar in Dallas. She is a LEED Green Associate and WELL Accredited Professional with over 10 years of experience across healthcare, environmental sustainability, and building performance. Connect with her on LinkedIn or visit citadelehs.com.
Citadel EHS protects people, property, and the environment — strengthening projects across their full lifecycle.