The rapid expansion of data centers associated with artificial intelligence, cloud computing, and digital infrastructure is creating a new and increasingly complex set of implementation challenges under the Clean Water Act (CWA). Although data centers have historically received limited attention within water quality regulatory programs, the scale, concentration, and operational demands of modern facilities are prompting state and federal regulators to reevaluate how existing CWA frameworks apply to these developments. Water-intensive cooling systems, large wastewater flows, growing reliance on reclaimed water, and significant supporting energy infrastructure are bringing data centers into closer intersection with nearly every major component of CWA implementation, including water quality standards, NPDES permitting, total maximum daily loads (TMDLs), water reuse programs, pretreatment requirements, and Sections 401 and 404 permitting authorities. This memo outlines the key issues, identifies emerging gaps, and highlights strategic considerations for state regulators and ACWA members.
DATA CENTERS - CWA Issues Outline
