What we know
The land, and the rules that govern it
From Hallam's zoning ordinance (Village Code Chapter 11), the Lancaster County Assessor,
and public reporting. The details matter, because this is where it gets fought.
The Phase 1 site
Monolith's Olive Creek campus on SW 42nd Street, about half a mile north of the
village. Roughly ten acres on the northeast portion, on ground already zoned for industry.
Who decides
Section 11-204: the Village Board controls zoning for all land inside the village
and within one mile of it. This is a village decision, not a county one.
What's being changed
Section 11-104(B): uses "may be added to a district upon application by a landowner and
upon proper amendment of the district regulations." The change attaches to an entire zoning
district — not to one parcel.
The Phase 2 ground
The parcel east of the campus is zoned AG — Agriculture District,
classed as agricultural and unimproved, per Lancaster County Assessor records. It was
acquired by a Lincoln limited liability company in August 2025.
Because it's zoned agricultural, a data center there requires its own
rezoning — with a hearing, notice to neighbors, and a vote. Unless this amendment takes that
away.
And the filed amendment reaches further than
one parcel. By its own words, it permits a data center on the same parcel as an industrial use
"or on a parcel adjacent to" it. The 135 acres east of the campus is one such
parcel — the one everyone is watching. It is not the only one. That language reaches
any ground that adjoins a parcel with an industrial use on it, whether or not
anyone is talking about it tonight. On every one of those parcels, the next data center would
arrive as an administrative site plan review — no hearing that matters, no notice to
neighbors, no vote. Nobody should be asked to give that up in a single meeting,
which is reason enough to vote no.
The best argument in their own code
They don't actually need this amendment
Hallam's ordinance already contains a
mechanism for exactly this situation. Sections 11-604(B)(14) and 11-605(B)(33) allow the
Village Board to approve "any similar use that is determined by the Village Board of
Trustees after referral to and recommendation by the Planning Commission to be of an
industrial nature similar to the above listed uses."
The board can already consider this one project, on its own merits,
without writing "data center" into our code forever. Ask them why they won't.
Water
The number nobody has mentioned
There is already a very large permitted
groundwater draw at this site. In 2021 the Lower Platte South Natural Resources District
approved three wells at Olive Creek estimated to pump about 420 million gallons a
year, used primarily for cooling. That was approved after nearly a year of testing
and study.
THE RANGE
Two cooling designs, wildly different
A data center cooled by evaporation runs roughly 2.6 million gallons per
megawatt per year. One closed-loop campus reports peak use around
22,000 gallons a day — against about 5,000,000 a day for
a comparable evaporative campus.
Same size facility. The difference is a design decision, and right now it is unwritten.
THE MATH
What that would mean here
At the 35 megawatts stated in the application, evaporative cooling
would run roughly 91 million gallons a year — on top of the 420 million
already permitted, and roughly ten times the water every household in Hallam uses combined.
If it's genuinely closed-loop, it's a rounding error. The application keeps both
options open.
Where these numbers come from
The 35 megawatt figure is stated in Monolith's own application. The 420 million gallon figure
is from the Natural Resources District's 2021 permit approval. The per-megawatt and
closed-loop figures come from published industry reporting. The village household comparison
assumes typical residential use for 268 people and is our estimate. We would rather be
corrected with a real water figure than rely on a range — which is the entire point.
The commitment that isn't one
"Where practicable"
The application commits to water-efficient
practices "including a closed-loop water cooling system or air-cooled
system, and water-saving fixtures where practicable."
Two escape hatches in one sentence. "Or" keeps
both designs available. "Where practicable" means the commitment applies only when the
applicant decides it does. Meanwhile the same application acknowledges there will be
wastewater discharges from cooling operations, regulated under a state
permit — which is not what "closed loop" suggests to anyone reading it plainly.
Strike "where practicable." Name the cooling system. If the plan really
is closed-loop, writing it down costs nothing.
The water ask
Give us the same process Monolith got
Before those 2021 wells were approved, the
Natural Resources District commissioned an independent review of the groundwater modeling,
held a public open house in Hallam, held a separate public input session, and took written
comment. It then attached conditions: flowmeters on every well, quarterly reporting,
groundwater monitoring before and after startup, and authority to add requirements if the
operation diverged from the application.
That was good enough for their own wells five years ago. It should be
good enough now.
- Disclose before deciding: peak megawatts, cooling method, projected
annual water use, and maximum daily withdrawal.
- Dry or fully closed-loop cooling written into the permit, with no
evaporative heat rejection anywhere in the system.
- An enforceable cap on maximum daily withdrawal, metered, reported
quarterly.
- Baseline monitoring of neighboring wells before operations begin.
- An independent review and a public input session — the 2021 standard.
One thing to understand about the Natural Resources District
It is not a veto. Under its own rules, if the district finds no detrimental effect on the
aquifer or on nearby wells, the permit "shall be granted." Showing up angry does not stop a
well permit — evidence does. That's why neighbors with their own wells matter more here than
anyone else, and why an independent hydrologist is worth more than a full room.
Noise
The limit on paper isn't the limit you'll live with
Hallam's code does set a noise limit. Section
11-603(E) caps industrial noise at 55 Leq where the receiving property is
residential, measured at the property line nearest the source. For scale, 55 is about steady
rain, or a conversation ten feet away. A vacuum cleaner is around 70 — and because decibels
aren't a straight scale, that's roughly three times as loud, not a little louder.
PROBLEM ONE
The same board that sets a limit can raise it
The 55 Leq standard is just another line in the same ordinance being amended right now.
Nothing makes it permanent. A future board can raise it, write an exception, or grant
relief — through the same process being used to add "data center" in the first place.
PROBLEM TWO
Enforcement is a bill the village pays
A limit only means something if somebody measures it. Who drives out at 2 a.m. with a
sound meter? Who buys the meter, hires the consultant, pays the attorney when a violation
is disputed? Those costs land on a village with a general fund of roughly $344,000.
A promise you have to sue someone to collect isn't a protection. It's a hope.
So what should we ask for instead?
Conditions that don't depend on the village policing them later: a hard setback distance
written into the permit, mandatory noise testing after construction paid for by the
applicant with a required fix if it fails, and money posted up front to cover enforcement and
removal. Distance and bonds enforce themselves.
Other levers in the same chapter
What the board can require, if it won't deny
- §11-602(D): a site plan must be filed for every industrial use, and
"the Village Board of Trustees may require additional standards as are necessary… for the
maximum protection of the environment and the health and safety of the citizens of the
village." Explicit authority to impose conditions.
- §11-1302: a zoning amendment application must state "the names and
addresses of all persons having legal or equitable interest in the property." If anyone
holds an option or purchase agreement on nearby ground, that should be on the record.
- §11-1304: "The burden of proof for any zoning change shall be upon the
applicant." Not on us.
- §11-603(G): a Lincoln-Lancaster County Health Department air permit is
required before a building permit issues.
- §11-110(E)(2): an industrial yard adjacent to residential use must be
increased to 75 feet with screening — a floor, not a ceiling. Other communities have
negotiated data center setbacks of 500 to 1,500 feet.