Data Centers and Their Energy Consumption: Frequently Asked Questions

Data Centers and Their Energy Consumption:

Frequently Asked Questions

Updated May 12, 2026

Congressional Research Service

https://crsreports.congress.gov

R48646

SUMMARY

Data Centers and Their Energy Consumption:

Frequently Asked Questions

In its simplest form, a data center is a physical facility that houses and runs large

computer systems. U.S. data center annual energy use in 2023 (not accounting for

cryptocurrency) was approximately 176 terawatt-hours (TWh), approximately 4.4% of

U.S. annual electricity consumption that year, according to a report by Lawrence

Berkeley National Laboratory. A data center typically contains multiple computer

servers, data storage devices, and network equipment that can provide information

technology (IT) infrastructure service for organizations to store, manage, process, and

transmit large amounts of data. Some projections show that data center energy

consumption could double or triple by 2028.

R48646

May 12, 2026

Martin C. Offutt

Analyst in Energy Policy

Ling Zhu

Specialist in Science and

Technology Policy

Ashley J. Lawson

Specialist in Energy Policy

Natalie R. Ortiz

Roughly one-half or greater of the electric power demand of data centers stems directly

Analyst in Government

Organization and

from the operation of electronic IT equipment. Much of the rest is for cooling. The

Management

operation of the IT equipment raises the temperature of the ambient room air,

necessitating a cooling strategy. Centralized cooling resources are of two types: (1) those

moving chilled air through large ductwork; or (2) those moving chilled water in a piped

cooling loop that exchanges heat with the environment. An alternative to these

centralized systems is room-scale air conditioners. One type, called computer room air conditioners (CRACs), is

common in smaller data centers. Exchanging the heat with the environment can happen faster with methods that

directly consume water. The source of the water can be the local water utility and can also be on-site reservoirs or

other colocated water resources. A study by the International Energy Agency estimates, for illustration, that a 100

megawatt U.S. data center may consume roughly 2 million liters (roughly 530,000 gallons) per day, averaged

across the various cooling strategies, with 725,000 liters (roughly 190,000 gallons) per day consumed on site, or a

little less than 40%.

Currently, there are no legally binding energy standards that apply explicitly to operation of data centers in the

private sector. For use within the federal government, the U.S. Department of Energy has published guidance on

how to optimize energy use in federal data centers. Another nonbinding program, ENERGY STAR, certifies data

centers with a focus on the building and infrastructure. Since 2012 the Department of Energy has regulated the

energy efficiency of CRACs, one type of cooling strategy.

The federal government has made some efforts to gather data using information collection methods suitable for

later scale-up. In general, before a federal agency can begin collecting information on data centers, the agency

must go through a months-long approval process under the Paperwork Reduction Act of 1995. A 2021 report by

the U.S. Energy Information Administration on a pilot study of energy use in data centers surveyed 50 facilities

and received 9 responses. Other options may include using data from private firms that maintain data sets that are

able to provide direct or proxy information on data centers.

In 2023, a letter from five Senators and three Representatives urged the U.S. Environmental Protection Agency to

use its authority under Section 114 of the Clean Air Act to implement a “mandatory disclosure regime” on

cryptocurrency mining facilities. In the 119th Congress, S. 1475, the Clean Cloud Act of 2025, introduced in the

Senate and referred to the Committee on Public Works, would amend the Clean Air Act (42 U.S.C. §§7401 et

seq.) to provide the U.S. Environmental Protection Agency and the U.S. Energy Information Administration with

authority to collect data and information on annual electricity consumption of data centers and cryptocurrency

mining facilities.

Congressional Research Service

Data Centers and Their Energy Consumption: Frequently Asked Questions

Contents

Introduction ..................................................................................................................................... 1

What is a data center? ...................................................................................................................... 1

What do data centers look like?....................................................................................................... 2

How have data centers been defined in federal law and guidance? ................................................ 2

What are the energy requirements of data centers? ......................................................................... 3

Why are data centers energy-intensive? .......................................................................................... 3

What equipment uses energy in a data center? ................................................................................ 5

What contributes to the need for cooling in data centers? ............................................................... 6

How are data centers typically cooled? ........................................................................................... 7

What are some additional data center cooling strategies? ............................................................... 8

What are some potential concerns about water consumption by data centers? ............................... 8

Which, if any, federal regulations cover the energy consumption of data centers?......................... 9

How do data centers affect electricity prices? ............................................................................... 10

How can policymakers address electricity affordability concerns?................................................ 11

Are there reports on the actual energy use of U.S. data centers? .................................................. 12

What statutory and administrative procedures apply to information collection in general? ......... 13

When collecting information about energy, what are specific considerations? ............................. 15

Figures

Figure 1. Notional Power Draws of IT Equipment and Infrastructure ............................................ 6

Contacts

Author Information........................................................................................................................ 17

Congressional Research Service

Data Centers and Their Energy Consumption: Frequently Asked Questions

Introduction

According to estimates produced by Lawrence Berkeley National Laboratory (LBNL), U.S. data

center annual energy use in 2023 (not accounting for cryptocurrency) was approximately 176

terawatt-hours (TWh), approximately 4.4% of U.S. annual electricity consumption that year.1

Some projections show that data center energy consumption could double or triple by 2028.2 Data

centers provide information technology (IT) infrastructure services for processing large amounts

of data, such as for the rapidly growing field of artificial intelligence (AI). Roughly one-half or

greater of the electric power demand of data centers stems directly from the operation of IT

equipment. Much of the rest is for cooling.

What is a data center?

In its simplest form, a data center is a physical facility that houses and runs large computer

systems. A data center typically contains multiple computer servers, data storage devices, and

network equipment that can provide IT infrastructure service for organizations to store, manage,

process, and transmit large amounts of data. An increasing number of private and public entities

have used data centers to support their expanding IT needs, particularly as data volumes continue

to grow.

Types of data centers vary based on their ownership or intended purposes. For example, a large

company may choose to build, own, and operate an on-premises data center (also known as an

“enterprise data center”) to house and manage its own IT infrastructure.3 Other organizations,

especially those lacking the space, staff, or IT resources, often choose to rent a space, equipment,

or services within a colocation data center (also known as a “managed data center”) owned and

operated by a third-party company.4 Some online service providers operate geographically

distributed and interconnected data centers and allow multiple users to remotely access

computing resources such as data processing chips, software, data storage, networks, and

applications hosted by these data centers, which are called “cloud data centers.”5 Cloud

computing service providers may also operate and maintain smaller data centers physically

located closer to end users (called “edge data centers”) to reduce network latency and data

communication delay, speed up content distribution, optimize real-time, data-intensive

workloads, and improve application performance and user experience.6

The increasing demand for data storage and processing capacities, especially for intensive

computational tasks such as AI development and deployment, has led to construction and

1 A. Shehabi et al., 2024 United States Data Center Energy Usage Report, Lawrence Berkeley National Laboratory

(LBNL), LBNL-2001637, December 2024, p. 5. While cryptocurrency is one type of service supported by data centers,

not all studies of energy consumption of data centers touch on energy usage related to cryptocurrency. The report noted

that its calculations assumed that data centers would operate consistently with how they were commissioned and

designed but that results may differ.

2 Shehabi et al., 2024 United States Data Center Energy Usage Report (LBNL report), p. 6. Does not include energy

use related to cryptocurrency.

3 Equinix, “What Is a Data Center? What Are Different Types of Data Centers?,” August 1, 2024,

https://blog.equinix.com/blog/2022/10/13/what-is-a-data-center-what-are-different-types-of-data-centers/.

4 Stephanie Susnjara and Ian Smalley, “What Is a Data Center?,” IBM, September 4, 2024, https://www.ibm.com/think/

topics/data-centers.

5 Cisco, “What Is a Data Center?,” https://www.cisco.com/c/en/us/solutions/data-center-virtualization/what-is-a-datacenter.html#~infrastructure-evolution.

6 Susnjara and Smalley, “What Is a Data Center?”

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Data Centers and Their Energy Consumption: Frequently Asked Questions

operation of “hyperscale data centers” notable for their size.7 According to industry analysts, to be

considered a hyperscale data center, a facility should contain at least 5,000 computer servers and

a large scale of network equipment and occupy at least 10,000 square feet of physical space, with

an electric power rating, sometimes referred to as power draw, exceeding 100 megawatts (MW;

one megawatt is equal to 1 million watts).8 Roughly 100 MW of electric power is sufficient to

support the electricity needs of 80,000 U.S. households.9

What do data centers look like?

Data centers have architectural configurations ranging from closets, to larger rooms within a

single enterprise, to dedicated standalone structures serving the needs of multiple customers or

tenants, known as colocation. Colocation centers are touted for their flexibility in allowing

customers to specify exactly the amount of hardware and software resources they require. The

largest, or “hyperscale,” facilities occupy whole buildings or groups of buildings. When reporting

on the number of data centers, some analysts only count whole-building data centers, which

would include the hyperscale and colocation centers. The majority of computer servers are found

in these latter two types of centers—74% in 2023, according to LBNL.10

How have data centers been defined in federal law

and guidance?

The term data center has been defined in federal laws and guidance in the context of energy

consumption and federal use of data centers. For instance, Section 453(a)(1) of the Energy

Independence and Security Act of 2007 (P.L. 110-140) defines a data center as “any facility that

primarily contains electronic equipment used to process, store, and transmit digital information,

which may be (A) a free-standing structure; or (B) a facility within a larger structure, that uses

environmental control equipment to maintain the proper conditions for the operation of electronic

equipment.”11

In its guidance memorandum for federal agencies to implement the Federal Data Center

Enhancement Act of 2023 (Division D, Title LIII, of P.L. 118-31), the Office of Management and

Budget (OMB) specified that an agency data center covered in the memorandum (1) is composed

of certain types of permanent structures and operates in a fixed location; (2) houses IT equipment,

including servers and other high-performance computing devices, or data storage devices; and (3)

7 Phill Powell and Ian Smalley, “What Is a Hyperscale Data Center?,” IBM, March 21, 2024, https://www.ibm.com/

think/topics/hyperscale-data-center.

8 Powell and Smalley, “What Is a Hyperscale Data Center?” See also VIAVI Solutions, “What Is a Hyperscale Data

Center?,” https://www.viavisolutions.com/en-us/resources/learning-center/what-hyperscale-data-center.

9 This calculation assumes a continuous source of electric power generation equal to 100 megawatts (MW), operating

year-round, and that the average U.S. household consumes 10,566 kilowatt-hours (kWh) of electricity per year. The

latter figure is sourced from the U.S. Energy Information Administration (EIA), “EIA Releases Consumption and

Expenditures Data from the Residential Energy Consumption Survey,” press release, March 29, 2023,

https://www.eia.gov/pressroom/releases/press530.php.

10 Shehabi et al., 2024 United States Data Center Energy Usage Report (LBNL report), p. 37.

11 42 U.S.C. §17112(a)(1).

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Data Centers and Their Energy Consumption: Frequently Asked Questions

hosts information and information systems accessed by other systems or by users on other

devices.12

What are the energy requirements of data centers?

The Department of Energy (DOE) examined the nationwide energy consumption of data centers

in response to direction by Congress in the Energy Act of 2020 (Section 1003 of Division Z, P.L.

116-260). The study, performed by LBNL, found that U.S. data center annual energy use in 2023

(not accounting for cryptocurrency) was approximately 176 terawatt-hours (TWh), approximately

4.4% of U.S. annual electricity consumption that year.13 An analysis by the Electric Power

Research Institute (EPRI) similarly estimated that data centers consumed 4% of U.S. electricity in

2023.14 In a separate analysis, in 2024, EPRI estimated that AI consumed 10% to 20% of data

center energy.15

Why are data centers energy-intensive?

Roughly one-half or greater of the electric power demand of data centers stems directly from the

operation of electronic IT equipment.16 Much of the rest is for cooling. The core hardware

components of a data center include computer servers, which contain computing chips (e.g.,

central processing unit [CPU] and graphics processing unit [GPU]), memory chips, data storage

drives, and network routers and switches.17 Data from a major CPU chip manufacturer show that

its data center-level CPU series in early 2025 had an average thermal design power (TDP) rating

between 150 watts (W) and 350W.18 An advanced data center-level GPU can have a maximum

TDP rating between 350W and 700W.19 The computing chips of CPU and GPU typically

consume the most electrical power inside a server, as discussed further in “What contributes to

the need for cooling in data centers?” According to an industry report published in November

12 Office of Management and Budget (OMB), Implementation Guidance for the Federal Data Center Enhancement

Act, M-25-03, January 14, 2025, p. 2, https://bidenwhitehouse.archives.gov/wp-content/uploads/2025/01/M-2503_Implementation-Guidance-for-the-Federal-Data-Center-Enhancement-Act.pdf.

13 Shehabi et al., 2024 United States Data Center Energy Usage Report (LBNL report), p. 5.

14 See Figure ES-1 of Electric Power Research Institute (EPRI), Powering Data Centers: U.S. Energy System and

Emissions Impacts of Growing Loads, October 2024, p. 3, https://www.epri.com/research/products/

000000003002031198.

15 EPRI, Powering Data Centers, p. 7.

16 Shehabi et al., 2024 United States Data Center Energy Usage Report (LBNL report), p. 47.

17 For more information on the use of CPUs and GPUs in data centers, see CRS In Focus IF12899, Data Centers and

Cloud Computing: Information Technology Infrastructure for Artificial Intelligence, by Ling Zhu.

18 Intel, “Intel Xeon 6 Processors,” https://www.intel.com/content/www/us/en/products/details/processors/xeon.html.

Intel defines thermal design power (TDP) as “the average power, in watts, the processor dissipates when operating at

Base Frequency with all cores active, under an Intel-defined, high-complexity workload.” Intel, “11th Gen Intel®

Core™ Mobile Processor Technical Specifications,” https://edc.intel.com/preview/content/www/us/en/products/

performance/benchmarks/11th-gen-intel-core-mobile-processor-technical-specifications/.

19 See, for example, Nvidia, “NVIDIA H100 Tensor Core GPU,” https://www.nvidia.com/en-us/data-center/h100/.

Nvidia defines the term TDP differently from Intel. The TDP of an Nvidia GPU is “the maximum power that a

subsystem is allowed to draw for a ‘real world’ application, and also the maximum amount of heat generated by the

component that the cooling system can dissipate under real-world conditions.” Nvidia, GeForce GPU Power Primer,

https://www.nvidia.com/content/dam/en-zz/Solutions/GeForce/technologies/frameview/Power_Primer.pdf.

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Data Centers and Their Energy Consumption: Frequently Asked Questions

2024, computing power and server systems account for roughly 40% of electricity consumption

in a data center, while network and data storage equipment use about 10%.20

Each piece of the electronic IT equipment generates heat as it operates. Many chipsets incorporate

a safety mechanism called “thermal throttling” that reduces the chip performance to prevent

overheating and protect the hardware.21 Data centers require cooling systems to help dissipate the

heat and maintain optimal performance and overall system stability. The cooling systems could

account for another 38% to 40% of electricity consumption in a data center.22 (See Figure 1.)

While general-purpose workloads typically require only CPUs, GPUs are typically considered

better than CPUs for handling computation-intensive processes such as AI training.23 Under full

workload conditions, a GPU performing AI training tasks may operate near its maximum capacity

and draw power close to its maximum TDP over extended periods of time.

The development and deployment of state-of-the-art, large AI models may require multiple GPUs

to work concurrently by distributing large volumes of data and computational tasks across the

computing chips (known as “parallel computing”).24 A study released in December 2024 observed

that, when training a large AI model using a computer system with eight advanced GPUs for eight

hours, the GPUs were near full utilization most of the time (an average of 93%) and the median

amount of electrical power consumed by the chips was 7.92 kilowatts (kW; one kilowatt is equal

to 1,000 watts), with a total energy consumption of 62 kilowatt-hours (kWh).25

Cutting-edge chip technologies support high-speed GPU-to-GPU data communication among

hundreds of GPUs across multiple servers, enabling the creation of a massive data processing

cluster to support large-scale AI training but also further increasing these data centers’ energy

consumption. A report released in April 2025 estimated that training a specific large AI model

required a total power draw of 25.3 MW and that the power required to train these models could

double annually.26 The report stated that “[t]he rising power consumption of AI models reflects

the trend of training on increasingly larger datasets.”27 Another study released in May 2025

estimated that training another large AI model consumed 50 gigawatt-hours (GWh; one gigawatthour is equal to 1 million kilowatt-hours) of energy, “enough to power San Francisco for three

days.”28

Multiple industry reports indicate that data processing demands of AI and related remote

computing services have spurred new construction and upgrades of data centers. The computing

20 Karthik Ramachandran et al., “As Generative AI Asks for More Power, Data Centers Seek More Reliable, Cleaner

Energy Solutions,” Deloitte Center for Technology Media and Telecommunications, November 19, 2024,

https://www2.deloitte.com/us/en/insights/industry/technology/technology-media-and-telecom-predictions/2025/genaipower-consumption-creates-need-for-more-sustainable-data-centers.html.

21 Intel, “What Is Throttling and How Can It Be Resolved?,” May 25, 2023, https://www.intel.com/content/www/us/en/

support/articles/000088048/processors.html.

22 Ramachandran et al., “As Generative AI Asks for More Power, Data Centers Seek More Reliable, Cleaner Energy

Solution.”

23 Imran Latif et al., “Empirical Measurements of AI Training Power Demand on a GPU-Accelerated Node,” arXiv,

December 20, 2024, https://arxiv.org/abs/2412.08602.

24 DigitalOcean, “Multi-GPU Computing: What It Is and How It Works,” February 14, 2025,

https://www.digitalocean.com/resources/articles/multi-gpu-computing.

25 Latif et al., “Empirical Measurements of AI Training Power Demand on a GPU-Accelerated Node,” p. 10.

26 Nestor Maslej et al., The Artificial Intelligence Index Report 2025, Institute for Human-Centered Artificial

Intelligence, Stanford University, April 2025, p. 72, https://hai.stanford.edu/ai-index/2025-ai-index-report.

27 Maslej et al., AI Index Report 2025, p. 72.

28 James O’Donnell and Casey Crownhart, “We Did the Math on AI’s Energy Footprint. Here’s The Story You Haven’t

Heard,” MIT Technology Review, May 20, 2025.

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Data Centers and Their Energy Consumption: Frequently Asked Questions

resources hosted by these centers would, in turn, lead to increased power demand. For example,

one report estimated that the computing capacity (measured by the amount of electrical power

consumed by IT equipment) of data centers under construction in North America at the end of

2024 reached a record-high 6,350 MW, more than double the figure from a year earlier.29 Another

report indicated that new hyperscale data centers have been built with capacities from 100 MW to

1,000 MW each, “roughly equivalent to the load from 80,000 to 800,000 homes.”30

What equipment uses energy in a data center?

Data centers in whole building structures contain energy-consuming IT equipment, cooling and

air handling equipment, and backup power supplies.31 The latter may include uninterruptible

power supplies, backup diesel generators, and natural-gas-powered generators.32 Backup

strategies involving batteries consume electricity while improving the quality of the electricity by

evening out the highs and lows of the electric voltage.

For a small data center within an office or research building, the mix of energy consumption

could be roughly 50% attributable to IT physical machines and 50% attributable to cooling and

power supply, according to a large industrial and energy equipment maker.33 (See Figure 1.) In

addition, data centers include appliances and equipment for human occupants, not depicted in the

figure. Overall, the energy use within data centers is not well described nationally, as elaborated

further in “Are there reports on the actual energy use of U.S. data centers?” An expression or

metric sometimes used to describe the energy performance of data centers is power usage

effectiveness (PUE), which is the ratio of all the power used by the data center to the power used

by just the IT equipment.34 For the example just discussed, the PUE would be two (2).

Discussion of IT equipment rapidly invokes terms descriptive of nonphysical entities such as

clouds, virtual machines, architectures, nodes, and protocols not directly associated with a realworld energy-consuming process. Understanding the energy consumption necessitates discussing

hardware (i.e., physical machines) to which energy consumption can be assigned, described

below in “What contributes to the need for cooling in data centers?”

29 CBRE, “North America Data Center Trends H2 2024: Surging Demand Drives Record New Data Center

Development,” February 26, 2025, https://www.cbre.com/insights/reports/north-america-data-center-trends-h2-2024.

30 EPRI, Powering Intelligence: Analyzing Artificial Intelligence and Data Center Energy Consumption, May 28, 2024,

p. 2.

31 These non-IT components may be termed “infrastructure” for purpose of energy tracking. A. Shehabi et al., “Data

Center Growth in the United States: Decoupling the Demand for Services from Electricity Use,” Environmental

Research Letters, vol. 13 (2018), p. 124030. Whole-building data centers are described elsewhere in the present report.

32 Uninterruptible power supply (UPS) strategies range from full standby to active regeneration of the waveform of the

power supply. CyberPower, “How Does an Uninterruptible Power Supply (UPS) Work?,” September 10, 2015,

https://www.cyberpowersystems.com/blog/how-does-a-ups-work/.

33 ABB, HVAC Motors: Motors in Data Centers, https://new.abb.com/motors-generators/nema-low-voltage-ac-motors/

hvac-motors.

34 The Green Grid, PUE: A Comprehensive Examination of the Metric, White Paper #49, 2012; and N. Casale, “Data

Centers: Where and How Should PUE Be Improved?,” ASHRAE Journal, vol. 63, no. 6 (June 2021).

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Data Centers and Their Energy Consumption: Frequently Asked Questions

Figure 1. Notional Power Draws of IT Equipment and Infrastructure

Illustrative case with PUE = 2, consistent with data centers of <150 square feet floor space

Source: CRS, adapted from ABB, HVAC Motors: Motors in Data Centers, https://new.abb.com/motors-generators/

nema-low-voltage-ac-motors/hvac-motors.

Notes: PUE = power usage effectiveness, the ratio of all power used by a data center to that used by the

information technology (IT) equipment (i.e., by servers, data storage, and communication). The depicted PUE of

2 is typical of a small data center (i.e., one having less than 150 square feet of floor space), as reported in

A. Shehabi et al., 2024 United States Data Center Energy Usage Report, Lawrence Berkeley National Laboratory

(LBNL), LBNL-2001637, December 2024, p. 47.

What contributes to the need for cooling in data

centers?

From an electrical engineer’s perspective, as computer chips of various types perform their

function, the impedance of the electrical pathways generates heat, both on and between chips.35

The majority of heat arises dynamically while the processers are performing useful functions.

Heat-generating activities from computation take place related to, or in support of, CPU/GPU

activity. Generally speaking, the energy consumption of a server scales according to the number

of CPUs or GPUs.36 On-chip (i.e., on the physical CPU/GPU) energy consumption includes

dynamic losses associated with the basic concept of operation of a transistor, known as

switching.37 Further losses occur associated with computing chips when they access on-chip

SRAM (static random access memory) and networking functions. Additional losses on-chip are

due to control functions (“clock”), power, and leakage current.38 Off-chip energy can be lost when

electricity moves between the computing chip (CPU/GPU) and a separate memory chip. The time

needed for very large transmission of data between separate chips, as in the last example, is

known as the memory wall or memory bottleneck.

Unlike in a desktop computer, the activity rates of chips in a data center can be extremely high,

and this activity rate increases the cooling needs as the hot equipment raises the temperature of

35 Servers, named after today’s client-server architecture, may include chips for computing, memory, and networking.

36 Shehabi et al., 2024 United States Data Center Energy Usage Report (LBNL report), p. 16.

37 Integrated circuits, also known as chips, contain billions of transistors. Heat is the movement of energy between two

bodies of different temperatures that are in thermal contact. Colloquially, heat may be referred to as a “loss” if the heat

does not provide a useful (valorized) service.

38 Leakage current is a static loss not associated with the chip’s performance of computational functions. Not all the

energy consumed by the IT equipment supports the useful computing functions of computer chips. Some energy heats

the equipment without performing a function.

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Data Centers and Their Energy Consumption: Frequently Asked Questions

the ambient air. The more common cooling strategies treat and condition this ambient air by

lowering its temperature and humidity.

Historically the amount of computing power per watt has improved significantly. The move to

multi-core processing at the turn of the millennium lowered the heat produced for the same

amount of computing power.39 According to Nvidia, as reported in October 2024, the prior 10

years had seen a 4,000-fold improvement in its GPU’s computational performance per watt of

power.40 More conservatively, the International Energy Agency estimates the change in AI GPU

performance per watt to have improved 100-fold or greater between 2008 and 2023.41

How are data centers typically cooled?

The operation of the IT equipment raises the temperature of the ambient room air, necessitating a

cooling strategy. Generally speaking, the cooling strategies for IT equipment differ from cooling

needed for personal comfort, with computer servers tolerant of higher temperatures but requiring

lower humidity.42 Federal guidelines and research advise using large centralized cooling resources

for data centers.43 There are two types of centralized cooling resources: (1) those moving air

through large ductwork to deliver chilled air and remove warm air; or (2) those moving water or

other heat transfer fluid through a piped cooling loop that exchanges heat with the environment.

The centralized cooling resources achieve higher efficiency at the larger scale. Those of the first

type, which moves air, can improve their energy efficiency by utilizing variable speed fans.44

Though less common, these methods can, if required, be used to heat the interior of the data

center using air-ducted or looped strategies (i.e., strategies that use heat transfer fluids).

An alternative to these centralized systems is room-scale air conditioners. One type, called

computer room air conditioners (CRACs), is common in smaller data centers.45 With CRACs, the

air is looped and filtered within the room but the heat is sent outside the building using refrigerant

or other fluid.46

The above methods rely on a sequence in which computing equipment first heats the room air,

after which the cooling system accepts heat from the room air, either moving a heated fluid

outside, where the heat is returned to the environment, or removing the air itself and replacing it

39 K. Bourzac, “Fixing AI’s Energy Crisis,” Nature, October 17, 2024.

40 K. Bourzac, “Fixing AI’s Energy Crisis.”

41 International Energy Agency (IEA), “Efficiency Improvement of AI Related Computer Chips, 2008-2023,”

October 17, 2024, https://www.iea.org/data-and-statistics/charts/efficiency-improvement-of-ai-related-computer-chips2008-2023.

42 See DOE’s proposed rule on computer room air conditioners, 65 Federal Register 48830 (August 9, 2000).

43 DOE Federal Energy Management Program (FEMP) and National Renewable Energy Laboratory (NREL), Best

Practices Guide for Energy-Efficient Data Center Design, July 2024, p. 14, https://www.energy.gov/femp/articles/bestpractices-guide-energy-efficient-data-center-design.

44 DOE FEMP, Best Practices, p. 16.

45 In DOE’s definition, CRACs are “[u]sed in computer rooms, data processing rooms, or other information

technology.” DOE FEMP, Best Practices, p. 14; and DOE, Technical Support Document: Energy Efficiency Program

for Commercial and Industrial Equipment: Certain Categories of Commercial Air Conditioning and Heating

Equipment, August 2019, p. 2-1.

46 Trane, Engineers Newsletter: Understanding the Selection of Direct Expansion (DX), vol. 52, no. 1 (March 2023),

https://www.trane.com/content/dam/Trane/Commercial/global/learning-center/engineers-newsletters/ADM-APN086EN.pdf; R. Waldron, “CRAC Units: Computer Room AC Basics,” Rasmussen Mechanical Services, January 25, 2023,

https://www.rasmech.com/blog/crac-units-computer-room-ac-basics/?srsltid=AfmBOoq5_rVIu-HmLF7BTN2i2AZ_d7bskeXWdYt4hzkS8WTuX75qFpy; and R. Schmidt and M. Iyengar, “Thermodynamics of

Information Technology Data Centers,” IBM Journal of Research and Development, vol. 53, no. 3 (August 2009).

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Data Centers and Their Energy Consumption: Frequently Asked Questions

with cooled return air. Exchanging the heat with the environment can happen faster with methods

that involve water.

What are some additional data center cooling

strategies?

High-performance computing (HPC)47 equipment has necessitated cooling methods that are

thermodynamically closer to the chips and intercept the energy before it has substantially raised

the room air temperature. These direct liquid cooling technologies can address the higher power

of HPC.

Another option that may be used during shoulder season (i.e., spring and fall in temperate

climates) or winter, known as free cooling, imports water chilled passively by environmental

conditions. Compared with methods involving conventional mechanical cooling that use powered

compressors, free cooling is relatively inexpensive. Optimizing the cooling of the data center will

generally involve some combination of methods.

Facilities with substantial cooling needs sometimes employ thermal storage. The National

Institutes of Health, for example, has a large chilled water storage facility at its Bethesda, MD,

campus.48 The thermal storage system operates by drawing down the chilled water reservoir

during periods of intense cooling requirements and replenishing the reservoir during off-peak

hours.

What are some potential concerns about water

consumption by data centers?

A study by the International Energy Agency estimates, for illustration, that a 100 MW U.S. data

center may consume roughly 2 million liters (roughly 530,000 gallons) per day, averaged across

the various cooling strategies, with 725,000 liters (roughly 190,000 gallons) per day consumed on

site, or a little less than 40%.49

Of the various cooling strategies to return heat to the environment, those that include cooling

towers accelerate the rate of heat transfer by spraying water onto surfaces in the cooling tower.

The water evaporates to provide cooling and must constantly be replenished. According to one

vendor, water-cooled systems may use as little as one-half the electric power of air-cooled

systems.50 The source of the cooling water can be the local water utility. A city in Oregon reported

47 The definition of high-performance computing is not rigorous but is associated with more complex tasks. See, for

example, Nvidia, “What Is High-Performance Computing?,” https://www.nvidia.com/en-us/glossary/highperformance-computing/.

48 National Academies of Sciences, Engineering, and Medicine, Managing the NIH Bethesda Campus Capital Assets

for Success in a Highly Competitive Global Biomedical Research Environment (National Academies Press, 2019),

p. 42.

49 IEA, Energy and AI: World Energy Outlook Special Report, April 2025, p. 242, https://iea.blob.core.windows.net/

assets/34eac603-ecf1-464f-b813-2ecceb8f81c2/EnergyandAI.pdf. IEA assumes a load factor of 55% for the data

center’s electricity consumption. IEA further employs a water intensity factor of 0.55 liters/kWh. Noelle Walsh-Elwell,

“How Microsoft Measures Datacenter Water and Energy Use to Improve Azure Cloud Sustainability,” Microsoft Azure

Blog, April 22, 2022, https://azure.microsoft.com/en-us/blog/how-microsoft-measures-datacenter-water-and-energyuse-to-improve-azure-cloud-sustainability/.

50 ABB, HVAC Motors: Motors in Data Centers, https://ibtinc.com/wp-content/uploads/2024/05/Brochure-Motors-indata-enters.pdf.

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that nearly 30% of the city’s water consumption was attributable to Google data centers, which

had tripled water consumption over a five-year period.51 The source of water can also be on-site

reservoirs or other colocated water resources.52 Data centers of smaller size within an office

building might only incrementally increase direct water use.

There are two principal sources of water demand from cooling towers. One of the sources of

demand is the sprayed-on cooling water just noted. Another operation, known as blowdown, uses

water to flush out hard scale that can build up on surfaces in the cooling tower when sprayed-on

water evaporates and leaves behind solid material.53 By one estimate, most of the wastewater

produced at a data center is from blowdown.54

Which, if any, federal regulations cover the energy

consumption of data centers?

DOE has published guidance on how to optimize energy use in data centers used by the federal

government.55 Currently there are no legally binding energy standards that apply explicitly to

operation of data centers in the private sector.56 The ENERGY STAR program, a voluntary

labeling program, certifies data centers with a focus on the energy efficiency of data centers’

buildings and infrastructure.57 ENERGY STAR uses a calculation method that effectively

removes the consumption of the IT equipment, attributing energy use only to that of a powered

shell (the building and its electricity).58 ENERGY STAR gives a rating based on the performance

of the powered shell of the building and rates this against that of similar buildings. The program

51 M. Rogoway, “Google’s Water Use Is Soaring in The Dalles, Records Show, with Two More Data Centers to

Come,” Oregonian, February 22, 2023. The city agreed to report “total of all water meter readings” for the operator of

the data center. Data released by the city in 2025 shows total water disposition was 355 million gallons attributed to

Google of the city’s 1.232 billion gallons (i.e., 29% was attributed to Google). April Ehrlich, “The Dalles’ Mayor

Called OPB’s Data Center Story Inaccurate. Here Are the Facts,” Oregon Public Broadcasting (OPB), January 23,

2026.

52 R. Miller, “Alligator Patrols Google’s Data Center,” DataCenter Knowledge, December 13, 2012,

https://www.datacenterknowledge.com/hyperscalers/alligator-patrols-google-s-data-center.

53 DOE FEMP, “Best Management Practice #10: Cooling Tower Management,” https://www.energy.gov/femp/bestmanagement-practice-10-cooling-tower-management.

54 DOE FEMP, “Best Management Practice #10: Cooling Tower Management,” https://www.energy.gov/femp/bestmanagement-practice-10-cooling-tower-management.

55 DOE FEMP, Best Practices.

56 Building codes and standards vary by jurisdiction. Generally, the federal government has jurisdiction over building

codes and standards for federal and military buildings; establishes national manufactured housing construction

standards; and requires buildings to comply with the Americans with Disabilities Act of 1990 (ADA; P.L. 101-336) and

the Fair Housing Act of 1968 (P.L. 90-284). For more information, see CRS Report R47665, Building Codes,

Standards, and Regulations: Frequently Asked Questions, coordinated by Linda R. Rowan.

57 For further information on ENERGY STAR, see CRS In Focus IF10753, ENERGY STAR Program, by Corrie E.

Clark.

58 ENERGY STAR, Data Center Estimates in the United States and Canada, August 2023, p. 1,

https://www.energystar.gov/sites/default/files/tools/Data_Center_Estimates_August_2018_EN%20%20508%20Blue.pdf. The whole-building certification by ENERGY STAR’s computation tool, Portfolio Manager,

takes account of electricity and natural gas used on site and calculates an energy use intensity (energy per floor area)

that includes the energy needed to generate and deliver the electricity and to deliver the natural gas.

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has certified nearly 300 data centers, with all but one having greater than 10,000 square feet total

floor area.59

ENERGY STAR also certifies products found in data centers such as enterprise scale servers,

uninterruptible power supplies, memory storage, and networking equipment.60

Since 2012, DOE has regulated the energy efficiency of CRACs.61 The regulatory program is

authorized by the Energy Policy and Conservation Act, as amended (EPCA; 42. U.S.C. §§6291 et

seq.). The standards apply to units at the time they are shipped by manufacturers; the

manufacturer is responsible for compliance.62

How do data centers affect electricity prices?

The price (rate) that customers pay for electricity is determined primarily by two factors: the cost

of producing electricity (generation) and the cost of delivering electricity to customers through

the grid (transmission and distribution).63 Utility regulators at the state or local level approve rates

that reflect a utility’s cost for these components. Rates typically change every few years in

response to shifts in utility costs over time. For example, if a utility invests in a new power plant

or in upgrades to the grid, rates might need to change to reflect those capital investments. Utility

sales also affect rates. When sales increase, a utility earns more revenue; conversely, when sales

decrease, a utility earns less revenue. If a utility’s revenue is less than its costs, rates might need

to increase to compensate. Similarly, if a utility’s revenue exceeds its costs, regulators might

lower rates.

Data center electricity demand could potentially affect electricity rates if that demand led to a

meaningful change in the local utility’s costs or sales (or both). If a utility built new infrastructure

to accommodate data center demand, the utility might raise rates to recover the cost.

Alternatively, if a utility had sufficient existing infrastructure to accommodate data center

demand, the increased sales might lead the utility to reduce rates.

Researchers at LBNL led an analysis providing insights on the extent to which data centers and

other drivers have affected retail electricity prices.64 Their analysis focused on the years 2019

through 2025. They found that the main driver behind increases in electricity prices during this

period was utility investments in grid infrastructure, mostly in response to aging infrastructure

and resilience needs. Other key drivers included natural gas prices, recovery from natural

disasters (e.g., storms, wildfires), and state energy and environmental policies. In other words,

this analysis did not identify data centers as major influencers of electricity prices in most areas of

the country between 2019 and 2025.

59 ENERGY STAR, ENERGY STAR Certified Data Centers, https://www.energystar.gov/buildings/certified-data-

centers.

60 ENERGY STAR, “Data Center Equipment,” https://www.energystar.gov/products/data_center_equipment.

61 The Energy Policy Act of 1992 (P.L. 102-486) amended the Energy Policy and Conservation Act (42 U.S.C. §6291

et seq.) and gave DOE authority to set energy conservation standards for “commercial package air conditioning and

heating equipment.” 42 U.S.C. §§6311(8)(A) and 6313(a)(6)(A).

62 See CRS Report R47038, The Department of Energy’s Appliance and Equipment Standards Program, by Martin C.

Offutt.

63 U.S. Energy Information Administration (EIA), “Electricity Explained: Factors Affecting Electricity Prices,”

https://www.eia.gov/energyexplained/electricity/prices-and-factors-affecting-prices.php.

64 Ryan Wiser et al., “Retail Electricity Price Trends and Drivers: Data Update—2026 Edition,” LBNL and the Brattle

Group, April 2026, https://emp.lbl.gov/sites/default/files/2026-03/Retail%20Price%20Trends_2026%20edition.pdf.

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The LBNL analysis further investigated the relationship between electricity demand growth

(including demand growth due to data centers) and prices. The analysis found that states with the

largest data center demand growth generally saw electricity price decreases between 2019 and

2025, though some states with relatively large data center growth saw price increases or little

change.65 One explanation for this finding may be that increased demand in some states allowed

utility costs to be spread over a larger sales volume, putting downward pressure on rates. Whether

that relationship holds in those states moving forward remains to be seen.

How can policymakers address electricity

affordability concerns?

Electricity consumers typically notice their monthly bill, not their electricity rate. Customers’

electricity bills are determined primarily as the product of electricity rates and electricity

consumption. Some policy options primarily impact rates while other options primarily impact

consumption.

State and local utility regulators can use policies to attempt to isolate the rate impact of utility

capital investment to data centers, thereby reducing any potential rate impacts for other

customers.66 This approach typically involves establishing new electricity customer classes for

data centers or other large electricity consumers with similar demand profiles. The number of

utilities with data center-specific policies is increasing as utility regulators around the country

address affordability concerns associated with data center development.67

Another set of policy options primarily impacting rates relates to infrastructure development. As

noted in the previous section, areas of the country with grid constraints due to insufficient

infrastructure are more likely to experience rate increases from new data center demand.

Electricity infrastructure is subject to a combination of federal, state, and local permitting

processes. Numerous proposals have been introduced in the 119th Congress with the goal of

speeding the pace of infrastructure development. For additional discussion, see CRS Report

R48762, Data Center Energy Infrastructure: Federal Permit Requirements, by Paul W. Parfomak

et al., and CRS Report R47627, Electricity Transmission Permitting Reform: Issues and

Legislative Proposals, by Ashley J. Lawson. Additionally, federal tax policy has historically

affected utility costs for new power plants, primarily by providing tax credits to developers of

power plants with low greenhouse gas emissions. The 119th Congress modified this policy. For

additional discussion, see CRS Insight IN12624, IRA Tax Credit Repeal in the FY2025

Reconciliation Law: Part 1, by Nicholas E. Buffie.

Policies aimed at increasing energy conservation and energy efficiency can reduce energy

consumption, thereby lowering consumers’ bills without necessarily affecting electricity rates.

Federal policy has historically promoted energy efficiency improvements through grant programs

and tax credits. States and utilities also frequently adopt policies promoting efficiency and

conservation. For additional discussion of selected federal programs, see CRS Report R46418,

65 Ryan Wiser et al., “Retail Electricity Price Trends and Drivers: Data Update—2026 Edition,” p. 47.

66 Such retail rate policies are outside federal jurisdiction, pursuant to the Federal Power Act (16 U.S.C. §§791 et seq.).

For additional discussion, see CRS In Focus IF11411, The Legal Framework of the Federal Power Act, by Adam Vann.

67 See, for example, Natalie Mims Frick and Long Lam, “Large Loads: Interconnection, Tariff Designs, and State

Actions,” LBNL and the Brattle Group, September 2025, https://www.brattle.com/wp-content/uploads/2025/09/LargeLoads-Interconnection-Tariff-Designs-and-State-Actions.pdf; and Smart Electric Power Alliance and NC Clean Energy

Technology Center, “Database of Emerging Large-Load Tariffs (DELTa),” https://sepapower.org/large-load-tariffsdatabase/.

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The Weatherization Assistance Program Formula, by Corrie E. Clark and Lynn J. Cunningham,

and CRS Insight IN12625, IRA Tax Credit Repeal in the FY2025 Reconciliation Law: Part 2, by

Nicholas E. Buffie.68

One consideration about these policies is the time period over which they can affect customers’

bills. Energy efficiency and conservation tend to have immediate impacts—electricity

consumption decreases as soon as an efficiency or conservation measure is in place. Policies

focused on infrastructure, in contrast, could take several years to affect rates because of the time it

takes to develop new electricity infrastructure.

Are there reports on the actual energy use of U.S.

data centers?

Owing to recent interest in the energy use of data centers, the federal government has begun data

collection to assess data centers’ scope and scale and, ultimately, their impacts on energy demand

and natural resources. Congress, through oversight and legislative activity, has shown interest in

the results of data collection and in expanding the federal government’s authority to collect the

data.69 As noted, the federal government has made some efforts to gather data using information

collection methods suitable for later scale-up.70 The Energy Information Administration (EIA) has

conducted two data collection activities, but these were limited by sample size or were curtailed.

A 2021 EIA pilot study of energy use in data centers surveyed 50 facilities and received 9

responses; other responses either were not received, were incomplete, or were not facilities

matching the criteria for data centers. EIA noted significant obstacles to collecting the data.71 EIA

focused on facilities of greater than 50,000 square feet as most likely to be whole-building data

centers.72

In 2024, EIA attempted to collect information focused on cryptocurrency mining data centers.

EIA began its survey with emergency approval under a provision of the Paperwork Reduction Act

of 1995 (PRA).73 The collection was challenged in the U.S. District Court for the Western District

of Texas by a trade association focused on blockchain and cryptocurrency technologies and a

Bitcoin mining company. These plaintiffs made several allegations against the government,

including that the PRA’s emergency approval provision was improperly used by EIA, that OMB’s

conditions for approving the collection violated the PRA,74 and that OMB violated the

Administrative Procedure Act (5 U.S.C. §551 et seq.) by arbitrarily and capriciously approving an

68 CRS Insight IN12625, IRA Tax Credit Repeal in the FY2025 Reconciliation Law: Part 2, by Nicholas E. Buffie.

69 See, for example, S. 1475, Clean Cloud Act of 2025; H.R. 6984, Data Center Transparency Act; H.R. 7858, Data

Center Community Impact Act; and Letter from Sens. Warren, Whitehouse, Markey, Merkley, and Durbin and Reps.

Huffman, Tlaib, and Porter to Michael Regan, Administrator, U.S. Environmental Protection Agency, and Jennifer

Granholm, Secretary, Department of Energy, February 6, 2023. In the 118 th Congress, see S. 3732, Artificial

Intelligence Environmental Impacts Act of 2024.

70 For further discussion of federal policies on information collection, see CRS Report R48546, The Office of

Information and Regulatory Affairs (OIRA): Overview and Major Responsibilities, coordinated by Meghan M. Stuessy

and Taylor N. Riccard.

71 EIA, 2018 CBECS Data Center Pilot, p. 2.

72 EIA, 2018 CBECS Data Center Pilot, p. 3.

73 44 U.S.C. §3507(j).

74 The role of OMB in approving an agency’s information collection, including surveys, is discussed below in “What

statutory and administrative procedures apply to information collection in general?”

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information collection that did not follow the PRA’s procedures.75 The court issued a temporary

restraining order, noting the allegations of harm made by plaintiffs, including the legal penalties

for not responding to the EIA survey,76 the costs of complying with the survey, and the disclosure

of proprietary information requested by EIA through the survey.77 Following the temporary

restraining order, EIA, OMB, and plaintiffs reached and filed an agreement with the district court,

resulting in an end to EIA’s data collection and EIA agreeing to destroy any data collected up to

that point.78

S. 1475, the Clean Cloud Act of 2025, introduced in the Senate and referred to the Committee on

Environment and Public Works, would amend the Clean Air Act (42 U.S.C. §§7401 et seq.) to

provide the U.S. Environmental Protection Agency (EPA) and EIA with authority to collect data

and information on annual energy consumption of the data center or cryptocurrency mining

facility, the provider of the electricity, any power purchase agreements, and related topics.

In 2023, a letter from five Senators and three Representatives urged EPA to use its authority under

Section 114 of the Clean Air Act to implement a “mandatory disclosure regime” on

cryptocurrency mining facilities.79 The letter asserted that some such facilities would emit greater

than the 25,000-ton threshold of carbon dioxide equivalent of greenhouse gases per year

necessary to invoke Section 114, an authority that allows EPA to request information from

emission source categories for regulatory development or enforcement and for other purposes.80

What statutory and administrative procedures apply

to information collection in general?

When an executive branch agency collects information or data from the public, the agency

typically must comply with the Paperwork Reduction Act of 1995.81 The PRA governs the

collection of information.82 The purpose of the PRA is to balance the government’s need for

75 Verified Complaint for Declaratory and Injunctive Relief, Tex. Blockchain Council v. Dep’t of Energy, No. 6:24-cv-

99 (W.D. Tex., February 22, 2024), ECF No. 1.

76 Plaintiffs cited 15 U.S.C. §797(a-b) in their complaint as the legal authority for the possible imposition of these

penalties, and cited to 10 C.F.R. §207.7(c)(1) for the maximum civil penalty amount that could be imposed for a

violation. At the time of the complaint, the maximum penalty was $12,937 per violation (see 89 Federal Register

1027). The amount is adjusted for inflation pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990

(P.L. 101-410), as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (P.L.

114-74, Title VII, §701 (129 Stat. 599)).

77 Order Granting Plaintiffs’ Motion for Temporary Restraining Order, Tex. Blockchain Council v. Dep’t of Energy,

No. 6:24-cv-99 (W.D. Tex., February 23, 2024), ECF No. 13.

78 Notice of Agreement, Tex. Blockchain Council v. Dep’t of Energy, No. 6:24-cv-99 (W.D. Tex., March 1, 2024),

ECF No. 24.

79 Letter from Sens. Warren, Whitehouse, Markey, Merkley, and Durbin and Reps. Huffman, Tlaib, and Porter to

Michael Regan, Administrator, U.S. Environmental Protection Agency, and Jennifer Granholm, Secretary, Department

of Energy, February 6, 2023.

80 42 U.S.C. §7414.

81 P.L. 104-13; codified at 44 U.S.C. §§3501-3521.

82 A collection of information “means the obtaining, causing to be obtained, soliciting, or requiring the disclosure to

third parties or the public, of facts or opinions by or for an agency, regardless of form or format, calling for either (i)

answers to identical questions posed to, or identical reporting or recordkeeping requirements imposed on, ten or more

persons, other than agencies, instrumentalities, or employees of the United States; or (ii) answers to questions posed to

agencies, instrumentalities, or employees of the United States which are to be used for general statistical purpose” (44

U.S.C. §3502(3)). For a more complete overview of the Paperwork Reduction Act’s (PRA’s) information collection

(continued...)

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information with the burden imposed on the public to produce and supply that information.83

Information collections include, but are not limited to, reporting or recordkeeping requirements,

surveys, public disclosure requirements, and collections that use an electronic or paper form.84

Before an agency can collect information from the public, the PRA requires approval by OMB.85

OMB’s approval is required regardless of whether the agency’s information collection is

mandatory (e.g., required by law) or voluntary.86 Information collections conducted in association

with a rule are also subject to OMB’s approval.87

The process for obtaining approval of an information collection—known in practice as the

clearance process—includes two public notice-and-comment periods. The first period is 60

days,88 during which time agencies are required to solicit the public’s input on certain topics,

including the practical utility, or usefulness, of the information to the agency,89 and the accuracy

of the agency’s burden estimate, or the amount of time and resources that is expected to be

expended by the public to generate, provide, or maintain the information for or to an agency.90 A

subsequent notice-and-comment period of at least 30 days occurs when the agency submits the

information collection request to OMB for approval.91

After receiving the information collection request from the agency and after the 30-day public

comment period has lapsed, OMB has up to another 30 days to make a decision on whether to

approve the information collection.92 Thus, under the PRA, an agency is expected to spend at

least 90 days and up to 120 days going through the clearance process. In practice, the total

amount of time spent by an agency is often much longer because internal agency processes

extend the timeline beyond what is specified in statute.

OMB can approve an information collection for no more than three years.93 When approval of an

information collection expires, an agency that wants to continue collecting the information must

go through the clearance process again and obtain OMB’s approval.94

As mentioned above, EIA obtained approval from OMB to collect data on cryptocurrency mining

data centers under the PRA’s emergency authorization provision, which was challenged in U.S.

district court.95 This provision of the PRA permits an agency in certain specified circumstances to

requirements, see CRS In Focus IF11837, The Paperwork Reduction Act and Federal Collections of Information: A

Brief Overview, by Maeve P. Carey and Natalie R. Ortiz.

83 44 U.S.C. §3501.

84 5 C.F.R. §1320.3(c)(1).

85 44 U.S.C. §3507(a)(2).

86 5 C.F.R. §1320.3(c).

87 44 U.S.C. §3507(d). See also 5 C.F.R. §1320.11 and §1320.12.

88 44 U.S.C. §3506(c)(2)(A).

89 44 U.S.C. §3502(11).

90 44 U.S.C. §3502(2). For a more complete discussion of burden under the PRA, see CRS In Focus IF12673, Burden

and the Paperwork Reduction Act: An Overview, by Natalie R. Ortiz.

91 44 U.S.C. §3507(b).

92 44 U.S.C. §3507(c)(2).

93 44 U.S.C. §3507(g).

94 Memorandum from Cass R. Sunstein, Administrator, Office of Information and Regulatory Affairs, to the heads of

executive departments and agencies, and independent regulatory agencies, “Information Collection under the

Paperwork Reduction Act,” April 7, 2010, pp. 5-6, https://obamawhitehouse.archives.gov/sites/default/files/omb/assets/

inforeg/PRAPrimer_04072010.pdf.

95 See footnote 73 and accompanying text.

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seek OMB’s approval to conduct an information collection on a temporary basis (not to exceed

180 days) without complying with the processes usually required under the PRA.96 In the district

court case brought against EIA, the plaintiffs alleged that EIA’s burden estimate was

underestimated and that EIA failed to take steps to minimize burden by not consulting with the

public as required by OMB in its regulations implementing the PRA.97

When collecting information about energy, what are

specific considerations?

There may be additional considerations beyond the PRA when it comes to the collection of

information on data centers’ energy use. For example, the Energy Supply and Environmental

Coordination Act of 1974 (ESECA; P.L. 93-319) includes an enforcement provision that imposes

civil monetary penalties on business entities that do not report energy information sought under

the information collection authorities of the Federal Energy Administrator.98 The possibility of

these civil monetary policies were part of the case brought against EIA when it attempted to

survey cryptomining facilities in 2024, as discussed above.99 The administrator’s information

collection authority contained in ESECA is “in addition to, independent of, not limited by, and not

in limitation of, any other authority of the Federal Energy Administrator.” Thus, while providing

information is anticipated to impose some cost under the PRA because of its conceptualization of

paperwork burden, additional costs are also possible for those that might be subject to reporting

energy information under ESECA. Other laws establishing an agency’s information collection

authority might also have an enforcement mechanism, which might be viewed as increasing the

stakes around collecting information in these circumstances.

In developing legislation addressing the collection of information about energy usage, Congress

may also give further consideration to which entities would be providing information. For

example, private firms maintain data sets that can provide direct or proxy information on data

centers. Cushman & Wakefield, a real estate firm with a specialty in data centers, and Baxtel, a

real estate and marketing firm that provides specialized services for data center owners, issue

reports on the population of data centers and their electric power requirements in the United

States. Obtaining data from these private firms may be one option.

Another option may be to obtain data from primary sources. While EIA previously attempted to

collect data directly from cryptomining facilities, the Clean Cloud Act of 2025 would require the

collection of information from three different sources: data centers, cryptomining facilities, and

the electric utilities that serve data centers and cryptomining facilities. Academic research has

found differences in the accuracy and reliability of data centers’ energy consumption estimates

because of differences in the methods used by the different sources of the estimates.100 The

96 44 U.S.C. §3507(j). While statute permits an agency to avoid the clearance process for emergency processing and

authorization, OMB’s regulations implementing the PRA state that an agency shall “set forth in the Federal Register”

the notice typically required unless waived or modified (5 C.F.R. §1320.13(d)). While statute permits OMB to provide

emergency authorization of an information collection for a maximum of 180 days, OMB’s regulations state that its

approval is valid for a maximum of 90 days (5 C.F.R. §1320.13(f)).

97 See the requirements for consult at 5 C.F.R. §1320.13(c).

98 15 U.S.C. §797 (P.L. 93-319, §12 (88 Stat. 264)). The functions of the Federal Energy Administrator were

transferred to the U.S. Energy Information Administration when EIA was established in 1977. For additional

information, see CRS Report R46524, The U.S. Energy Information Administration, coordinated by Ashley J. Lawson.

99 See footnote 73 and accompanying text.

100 David Mytton and Masaō Ashtine, “Sources of Data Center Energy Estimates: A Comprehensive Review,” Joule,

vol. 6, no. 9 (September 2022), pp. 2032-2056.

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authors of the study find that these estimates are then used by others in subsequent research, and

the authors argue that these data quality issues could undermine the research that subsequently

uses these estimates.101

One possible policy implication that follows from the aforementioned study is that how

information is collected could have consequences for the subsequent uses of that information,

including the extent to which it can be used as an authoritative source to inform federal energy

policy or regulation. In other words, how statute directs the collection of information on data

centers’ energy use, or how an agency designs its collection of information on such energy use,

may influence the extent to which such collected data can then be used to reliably serve certain

purposes. The data, for example, may be not be generalizable, may be incomplete (e.g., certain

information is missing or underreported), inaccurate (e.g., certain information is underestimated

or overestimated), or otherwise limited in its usefulness because of circumstances that occurred

during data collection.

The use of data collected by federal agencies on energy use is not necessarily without

consequence or significance. The Clean Cloud Act of 2025 would establish that the information

collected under it shall be used for fee setting. Additionally, compliance with a certain provision

of the Clean Cloud Act of 2025 is to be monitored by the EPA, in conjunction with EIA, using

“the best available data,” including the information collected under the bill.

The Clean Cloud Act of 2025 would also require certain data collected under it to be made

publicly available. Some researchers argue that it is insufficient and possibly ineffective for

policymakers to establish data policy regimes that are primarily concerned with information

disclosure (e.g., making certain data from regulated entities publicly available in databases,

repositories, or similar searchable publications and websites).102 Instead, it is argued that

policymakers should focus on the broader goals of a “data stewardship” regime. Data stewardship

would aim to maximize data quality and usability—alongside information disclosure and making

data publicly available—by ensuring the reliability, accuracy, and fairness of data collected, so

that the data can serve regulatory needs and the various ends and goals of stakeholders and data

users.103

Another potential consideration is that the Information Quality Act (IQA) required OMB to

develop government-wide guidelines for information and data quality.104 In implementing the

IQA, OMB acknowledged that certain information developed or made publicly available by

agencies should be held to a higher quality standard because it is more important and influential,

and that increasing data quality has costs and benefits.105

101 See also the discussion about data gaps and analytical errors in research on the environmental impacts of

information technology (IT) in Jonathan Koomey and Eric Masanet, “Does Not Compute: Avoiding Pitfalls Assessing

the Internet’s Energy and Carbon Impacts,” Joule, vol. 5 no. 7 (July 2021), p. 1626. These authors argue, “A recurrent

theme is that well-intentioned research often overestimates IT’s electricity use and climate impacts, sometimes by

orders of magnitude. These results then become ‘factoids’ that spread quickly as people share them and the media

report them” (p. 1625).

102 Nathan Cortez, “Regulation by Database,” University of Colorado Law Review, vol. 89, no. 1 (2018), pp. 28-37.

Hereinafter cited as “Cortez, “Regulation by Database.”

103 Cortez, “Regulation by Database,” pp. 69-91.

104 P.L. 106-554, Appendix C, §515 (114 Stat. 2763A-153).

105 OMB, “Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information

Disseminated by Federal Agencies; Republication,” 67 Federal Register 8452-8453, February 22, 2002,

https://www.federalregister.gov/documents/2002/02/22/R2-59/guidelines-for-ensuring-and-maximizing-the-qualityobjectivity-utility-and-integrity-of-information.

Congressional Research Service

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Data Centers and Their Energy Consumption: Frequently Asked Questions

Author Information

Martin C. Offutt

Analyst in Energy Policy

Ashley J. Lawson

Specialist in Energy Policy

Ling Zhu

Specialist in Science and Technology Policy

Natalie R. Ortiz

Analyst in Government Organization and

Management

Acknowledgments

Mari Lee prepared the graphic.

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Congressional Research Service

R48646 · VERSION 8 · UPDATED

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