Under What Conditions Does a Data Center Make Sense?

A collaboration between Lewis McLain & AI

It’s Not Only the Gallons — It’s the Peak: Peak Demand, Utility Capacity, and the Terms That Protect a Community

A plain-English technical paper · July 2026

Executive Summary

Headlines about data centers quote annual totals — millions of gallons, megawatts “equal to a small city.” Those totals are real, but they point at the wrong risk. Utility systems are built, and financed with decades of debt, to survive their single worst day. Capacity built for that day must be paid for all year, every year, whether or not the water or power is ever sold. So the first question about any data center is not “how much will it use?” It is “how big must we build — and who pays for what stands idle?”

Three findings follow, developed one step at a time in the body of the paper:

  • On electricity, data centers are among the steadiest, cheapest-to-serve customers a utility can sign. The real electric-side issues are sheer size, capacity reserved but never used, and split-second power swings from AI computing — all manageable by contract.
  • On water, the opposite. The newest cooling designs cut annual gallons dramatically but concentrate demand into a few hot weeks — so a facility that looks small on annual volume can force a community to build big-city capacity that sits idle most of the year, and its wastewater brings its own peak and its own chemistry.
  • Block one path and the demand moves to another network. Denied water, a data center leans harder on the electric peak; denied grid power, it builds gas-fired generation that lands on the pipeline system’s worst winter morning — and needs water of its own. Water, electricity, and gas must be evaluated as one decision.

Two more conclusions complete the picture. First, where the underlying supply — the water in the watershed, the generation on the grid, the gas in the pipe — is genuinely short, totals do matter, and the honest remedy is curtailment shared evenhandedly by all users, not a ban on the newest arrival. Second, the benefits are just as real as the burdens: a data center can be the best-shaped utility customer a system has ever been offered and a major tax base that demands almost nothing in services. Every major objection has a practical fix that can be written into a contract — including, for the water peak, a storage tank costing the developer roughly one percent of the project. The right answer to a well-sited data center proposal is neither “no” nor an unexamined “yes.” It is “yes, if” — and this paper ends with the term sheet.

1. Introduction

Public debate about data centers has focused overwhelmingly on totals: millions of gallons of water per year, or electricity use “equal to a small city.” Totals make good headlines, but they describe the wrong risk. A utility is rarely crippled by how much its customers use over a year. It is crippled — or forced into expensive expansion — by how much all of its customers demand at the same moment, on the system’s single worst day.

The question is no longer academic, and it is not on the horizon — it is here, and policymakers at every level are moving. At least eleven states have weighed moratoriums; New York’s legislature has passed the nation’s first statewide pause, awaiting the governor’s signature; Maine’s governor vetoed a similar bill; and in Texas, the Public Utility Commission and the Texas Water Development Board are surveying existing and planned data centers about water use and treatment, with a PUC report due to the Legislative Budget Board and the Governor at the end of 2026 [15][22]. The scale in Texas alone frames the stakes:

Texas snapshotFigure
Data centers operating (2025)400+, concentrated in five regions: Dallas–Fort Worth (197), San Antonio (60), West Texas (59), Austin (53), Houston (48)
Water use by Texas data centers, 2025≈25 billion gallons
Projected water use by 203029–161 billion gallons per year — up to ≈2.7% of all Texas water use
Electricity demand today≈9,500 MW
Projected electricity demand, 2030≈22,000–78,000 MW (ERCOT forecast range)
The planning gapERCOT has a process for interconnecting large electric loads; no parallel statewide process yet exists for water

The scale of the question — Texas snapshot [22][23].

This paper explains why load factor, not annual usage, is the master variable in utility economics — and where that rule stops, because in supply-constrained regions totals do matter; examines what published data show about data center demand for electricity, water, and natural gas; traces the consequences for community capital budgets, utility rates, and municipal credit; and then turns the argument around, examining the substantial benefits data centers offer and the engineering and contractual tools that can neutralize each major objection. The subject is genuinely technical, and this paper does not pretend otherwise; the approach is to take it one step at a time, define every term on first use, and end each section with a Key Takeaway box for the reader who wants the point without the plumbing.

KEY TAKEAWAY — The risk to a community is not how much a data center uses in a year; it is how big a system must be built — and financed — to stand ready for its single worst day. That question has now reached legislatures and governors, and Texas agencies owe the Governor a report on it at the end of 2026.

2. Utility Economics 101: Systems Are Built for the Peak, Not the Average

2.1 Two kinds of cost

Every utility has two fundamentally different kinds of cost. Operating costs — fuel, treatment chemicals, pumping energy — rise and fall with how much product is actually delivered. Capital costs are different: they are the cost of building the system itself — the treatment plants, storage tanks, pipes, generating stations, wires, and substations. Capital costs are driven almost entirely by capacity, and capacity is set by expected peak demand plus a safety margin, not by average or total demand [12].

The intuition is everyday. A church kitchen is sized for Easter Sunday, not the average Tuesday. A highway is sized for rush hour, not 3 a.m. A water system must be able to treat and deliver the maximum-day demand, sustain the peak hour within that day, and still hold reserve for firefighting during a heat wave [1]. An electric grid must meet the single highest hour of the year, typically a summer afternoon when air conditioners are running everywhere at once. All of that capacity must be built, financed, and maintained year-round, even though much of it is idle most of the time. The debt service on a treatment plant is due every month; the plant only earns its keep on the days it runs hard.

2.2 One concept, two vocabularies — and the convention used in this paper

The electric and water industries measure the same idea from opposite directions, which causes endless confusion. The electric industry speaks of load factor — average demand divided by peak demand, so higher means flatter. The water industry speaks of peaking factor — maximum-day demand divided by average-day demand, so lower means flatter. One is simply the reciprocal of the other: a peaking factor of 4.0 is a load factor of 25 percent. They are two ways of looking at one critical concept: what share of the capacity reserved for a customer is actually used. To be consistent and as simple as possible, this paper uses load factor throughout, converting water-industry peaking factors wherever sources report them (load factor = 1 ÷ peaking factor). Table 1 sorts out the terms.

TermDefinitionA perfectly flat customer
Load factorAverage demand ÷ peak demand, usually over a year. Higher is flatter and cheaper to serve. Used throughout this paper for water, electricity, and gas alike.100%
Peaking factorMaximum-day demand ÷ average-day demand — the water industry’s customary metric. The reciprocal of load factor: a peaking factor of 4.0 equals a 25% load factor. Converted to load factor throughout this paper.1.0
Peak-hour factorPeak-hour flow ÷ average flow; derived from daily figures with additional multipliers; sizes pumps and storage.1.0
Coincident peakA customer’s demand at the moment of the whole system’s peak — the demand that actually drives system-wide capacity.Equal to its average

Table 1. Key terms. Load factor and peaking factor are reciprocal expressions of the same ratio; this paper standardizes on load factor [1][2][12].

2.3 A worked example: same gallons, six times the cost

Consider two industrial customers who each buy exactly 36.5 million gallons per year — identical annual volume, identical volumetric revenue to the utility. Customer A draws a steady 100,000 gallons every day: a 100 percent load factor. Customer B averages the same 100,000 gallons per day but spikes to 600,000 gallons on the hottest days of summer: a load factor of just 17 percent.

 Customer A (flat)Customer B (peaky)
Annual purchases36.5 million gallons36.5 million gallons
Average-day demand100,000 gal/day100,000 gal/day
Maximum-day demand100,000 gal/day600,000 gal/day
Load factor100%17%
Capacity the utility must build100,000 gal/day600,000 gal/day
Capacity cost per gallon actually sold1x6x

Table 2. Two customers with identical annual usage. Customer B forces the utility to build six times the capacity for the same sales.

If the utility recovers costs mainly through volumetric rates — dollars per thousand gallons — both customers pay the same, yet Customer B caused six times the capital requirement. The difference does not vanish; it is silently financed by every other ratepayer, embedded in general rates or in system-wide debt. This is the peaking problem in one sentence: capacity is what a community pays for, while usage is merely what the utility happens to sell. Worse, the capacity built for Customer B’s few hot days stands idle roughly 360 days a year while bondholders are paid on all 365.

2.4 A necessary distinction: supply versus capacity

Before the load-factor argument can be applied honestly, two different scarcities must be kept separate, because they are routinely conflated in public debate. The first is delivery capacity — the size of the treatment plant, the pipe, the wire, the pipeline. Capacity is a manufactured thing: a community can build more of it, and what drives its cost is peak demand. That is the subject of this paper. The second scarcity is the commodity itself — the water actually in the watershed or aquifer, the gas actually deliverable from the basin, the energy actually generatable over a year. Supply is not manufactured on demand, and what strains it is total consumption, not peaks.

Where supply is genuinely short — a drought-stressed river basin in the Southwest, a pipeline-constrained region in a deep freeze, a grid short of generation — total usage is a legitimate, binding concern, and no rate design can conjure water that does not exist. But the remedy in a supply crisis is fundamentally different: curtailment and allocation applied evenhandedly to all users — industrial, commercial, and residential alike — because a shortage of supply is a community problem, not a data center problem. A large flat customer did not cause the drought, and a moratorium on one industry does not refill the reservoir; it merely reassigns who gets to consume a fixed shortfall.

The practical sequence for any community evaluating a large-load proposal therefore has two steps. Step one is a supply adequacy assessment: how much firm water, generation, and gas supply actually exists under stress conditions — drought of record, heat wave, polar vortex — and how much is already committed? If that test fails, the conversation is about curtailment rules for everyone, and it should be had openly rather than through the back door of blocking whichever large customer arrived last. Step two, where supply is adequate, is the subject of the rest of this paper: the binding economics become peak-driven capacity, and the task is to make the customer who causes the peak pay for the peak.

KEY TAKEAWAY — Capacity is what a community pays for; usage is what it happens to sell. A customer’s load factor — how flat its demand is — decides its true cost to the system. And before any of that: verify the supply exists, because a supply shortage is everyone’s problem, not one industry’s.

3. Electricity: The Surprisingly Flat Customer

3.1 What the data show

The popular image of a data center is a building running flat-out, 24/7/365. On the electric side, that image is close enough to true that it works in the data center’s favor. Utilities and analysts commonly assume load factors of 90 to 100 percent for large data centers [2]. Utility planning practice is somewhat more conservative: Duke Energy plans for new large loads at about an 80 percent load factor, and Dominion reported roughly an 82 percent actual load factor for large data centers in Virginia in 2024 [3]. Metered results vary more than the folklore suggests — one analysis of actual facilities found fewer than half exceeded an 80 percent load factor [2][3] — but even so, data centers remain far flatter than almost any other customer class. Published figures translate to electric load factors of roughly 50 to 65 percent for conventional cloud data centers and close to 100 percent for AI training facilities, whose accelerators grind at near-constant power for weeks at a time [4].

In classic rate-making terms, a high-load-factor customer is the cheapest kind to serve per kilowatt-hour: the demand-related capital cost is spread across an enormous number of kilowatt-hours. On the traditional load-factor test — the same test that condemns them on water, as Section 4 shows — data centers pass with room to spare.

3.2 The three real electric-side problems

First, scale and coincidence. A flat load contributes its entire demand to the system’s coincident peak. A 500 MW data center at a 90 percent load factor still adds up to 500 MW to the summer peak hour, and the grid must build for it. Flatness spreads the cost over more energy; it does not shrink the capacity requirement.

Second, contracted versus realized demand. Load factor is measured against a facility’s realized peak, but the utility must build to its contracted (nameplate) capacity. If a facility’s realized peak is only 80 percent of its contract and its load factor is 90 percent, its true utilization of the capacity the utility stands ready to serve is only 72 percent [2]. Facilities also routinely over-request capacity to preserve room for growth, and they ramp up over years. The gap between what is reserved and what is used is a hidden peaking problem, and it is why minimum-demand charges, ratchets, and take-or-pay provisions exist.

Third, fast transients. AI training clusters synchronize tens of thousands of processors, producing quasi-periodic power swings every 2 to 6 seconds that can oscillate by tens of megawatts within a single facility, with ramps measured in tens to hundreds of megawatts per second at job starts, checkpoints, and failures [4][5][6][7]. These sub-minute swings do not show up in a monthly demand charge at all — they are a power-quality and grid-stability problem, a new kind of “peaking” measured in seconds rather than seasons.

3.3 Proof that peaks, not energy, are the scarce resource

Researchers at Duke University quantified how much slack lives inside existing grids if new loads simply avoid the worst hours: about 76 gigawatts of new load — roughly 10 percent of the entire U.S. aggregate peak — could be added to existing systems if that load curtailed just 0.25 percent of its annual energy, about 85 hours per year in events averaging two hours [8]. Nearly all of the grid’s spare room is hiding in the hours that are not the peak. The same insight, mirrored, explains the water problem in the next section.

KEY TAKEAWAY — On electricity, data centers are among the flattest, cheapest-to-serve customers ever offered to a utility. The real electric-side issues are sheer size at the system peak, capacity reserved but never used, and split-second power swings — each manageable by contract.

4. Water: Where the Peaking Problem Lives

4.1 Why constant cooling does not mean constant water

A natural objection runs: a data center needs cooling 24 hours a day, all year — so surely its water demand is flat, like its electricity. The premise is right and the conclusion is wrong, because water is not how most of the cooling is done. It is the peaking fuel.

Physics sets the terms. Essentially every watt of electricity entering the building becomes heat, and that heat must leave the building continuously. There are only two ways to dump heat into the environment: blow outside air across coils (dry cooling — no water consumed), or evaporate water, which absorbs roughly 8,000 Btu per gallon — the same trick the human body uses when it sweats [1][12]. Dry cooling works fine when outside air is cool. It falters exactly when it is 105°F outside, because you are trying to push heat into air nearly as hot as the equipment. Evaporation keeps working in extreme heat because it exploits the humidity-adjusted (“wet-bulb”) temperature, which stays well below the air temperature. So water demand tracks the weather, not the computing load.

4.2 But is the water not recirculated?

Inside the building, yes. Modern facilities — especially liquid-cooled AI facilities — run closed loops in which the same water is chilled and recirculated indefinitely; that water is bought once [13]. But chilling the loop does not destroy the heat, it only moves it to the edge of the building, where it must still be rejected to the outdoors by one of the same two paths: fans (electricity) or evaporation (water). Even a cooling tower recirculates its water many times — but on each pass a fraction evaporates, and a further portion must be deliberately drained and replaced (“blowdown”) to keep dissolved minerals from scaling the equipment. Recirculation dramatically reduces water withdrawal; it cannot eliminate consumption where evaporation does the work [1][12][13].

4.3 The paradox: designs that use less water use it more peakily

The dominant new design is dry cooling with evaporative assist: fans handle the heat load whenever ambient temperatures allow — typically 85 to 95 percent of the hours of the year — and water sprays switch on only during the hottest hours, when dry cooling alone cannot keep up [1]. This slashes annual water use, which is what operators advertise. But it concentrates the entire year’s water demand into a few hundred summer hours. Annual gallons went down; the maximum-day demand the water utility must be built to serve did not. The water load factor collapses — from roughly 45 percent for a conventional cooling tower into the teens or below.

Facility / systemCooling typeWater load factor
Typical residential and commercial users (benchmark)40 – 67%
The Dalles, OR pressure zone dominated by a hyperscale data center (measured)Evaporative cooling towers45%
Phoenix, AZ colocation facility (estimated)Evaporative cooling towers≤ 45%
West Des Moines, IA hyperscaler (measured monthly 23%; estimated daily)Dry with evaporative assist≤ 15%
Planned AI data center, Indiana innovation district (planning)Dry with evaporative assist≤ 16%
Leesburg, VA hyperscale campus (planning, inferred)Dry with evaporative assist≈ 12% or lower
Data centers in Prince William Water service area, VA (measured, 2024)Mixed fleet10%
Northern Virginia weighted actual, many facilities combinedMixed fleet27 – 29%
Wisconsin AI campus: 0.7 MGD capacity requested vs. ≈23,000 gal/day averageDry with evaporative assist (≈480 hrs/yr of water use)< 3.5%
Leading operators’ planning values for state-of-the-art facilitiesDry with evaporative assist12 – 17% or lower

Table 3. Documented data center water load factors (average-day demand ÷ maximum-day demand). Source documents report daily peaking factors; converted here as load factor = 1 ÷ peaking factor. All figures compiled in [1] from utility records, government filings, and planning documents.

Two rows deserve emphasis. The West Des Moines facility uses relatively little water in winter, yet its summer draw is so large that it became the utility’s single largest annual water customer in 2024 and 2025 — a low load factor and large scale compounding [1][9]. And the Wisconsin campus is the design taken to its logical extreme: in a cold climate, evaporative assist is expected to run only about 480 hours per year, so the facility averages a trivial 23,000 gallons per day while requiring the utility to stand ready to deliver 700,000 gallons per day — a water load factor of barely 3 percent. By annual volume it is a small customer. By the capacity the community must reserve for it, it is enormous. That single contrast is the central point of this paper.

4.4 The worst timing possible

These peaks are not randomly timed. Evaporative assist switches on during prolonged heat waves — precisely when lawns are being irrigated, municipal demand is at its annual maximum, drought restrictions may be in force, and fire risk is elevated. The data center’s peak lands on top of everyone else’s peak, so it adds almost gallon-for-gallon to the system’s design day. And unlike electricity, where batteries can shave short peaks, operators have rarely built multi-day water storage voluntarily [1] — under volumetric rates, there is no reason to; the utility bears the peak. Section 9 shows how sharply that economics changes once the peak is priced.

4.5 The return trip: wastewater has its own peak and its own chemistry

What a data center sends back down the sewer deserves the same scrutiny as what it takes in. Cooling blowdown is concentrated by design: the same gallons that cycled through the towers return with elevated dissolved minerals and salts, along with residues of the biocides and corrosion inhibitors used to protect the equipment — compounds containing phosphates, nitrites, and heavy metals that stress municipal treatment plants, raise treatment costs, and can threaten permit compliance downstream [22]. Regional wholesale providers are explicit on this point: the North Texas Municipal Water District advises member cities to engage its planning and wastewater pretreatment teams early — before site plans are approved, not after [22].

And the return flow is peaky too, for the same reason the intake is: blowdown scales with evaporative operation, which is concentrated in the hottest weeks. At the Wisconsin campus discussed above, the planned wastewater discharge pattern implies a load factor of roughly 7 percent [1] — the sewer plant, like the water plant, must be sized for a worst day that arrives only a few times a year. The remedies are standard industrial-pretreatment tools, applied before approval: discharge permits with concentration and flow limits, pretreatment requirements, surcharges tied to strength and peak flow, and early coordination with the wholesale treatment provider [22].

KEY TAKEAWAY — Cooling runs 24/7; water demand does not. Modern designs cut annual gallons but concentrate demand into heat waves — water load factors of 3–17% — and the wastewater comes back with its own peak and its own chemistry. Engage the treatment provider before the site plan is approved.

5. What Peaks Cost a Community

Water systems are sized by three peak-driven standards: treatment and supply for the maximum day, pumping and storage for the peak hour, and reserve capacity for fire flow — all with safety margins for heat waves and drought [1]. Every one of those design parameters is set by peak demand. None is set by annual volume.

The capital sums are not abstract. In one Indiana economic-development district, adding 25 million gallons per day (MGD) of supply and 15 MGD of wastewater treatment is expected to take about six years and cost over $1 billion — and a single technology company’s data center holds 8 MGD, roughly a third, of the new allocation [1]. In Wisconsin, a data center developer’s request for 1.2 MGD triggered over $100 million in upgrades in a town whose entire remaining system capacity was under 2 MGD [1]. Three recent water infrastructure upgrades for large technology companies together approached $1 billion; in Louisiana, one company committed up to $400 million toward public water infrastructure serving its new campuses [1]. Nationally, U.S. data centers are projected to need roughly 700 to 1,450 MGD of new water capacity by 2030, with an estimated infrastructure valuation reaching as high as $58 billion — landing on public systems that already face a $1.3 trillion-plus, twenty-year funding backlog, in a country where 12 to 19 million households already lack affordable water service [1][11].

Rate design determines who bears these costs. Volumetric rates and gallonage-based impact fees systematically under-recover from low-load-factor customers, because — as Table 2 showed — such customers cause capacity costs far out of proportion to the water they buy. The under-recovery is not returned to anyone; it is spread across the remaining ratepayers as higher general rates or added system debt. The remedies are the water-sector equivalents of tools the electric industry has used for a century: capacity or demand charges based on each customer’s allocated maximum-day capacity; ratchet provisions so that a customer who sets a peak keeps paying for it; take-or-pay contracts and developer-funded infrastructure agreements; and impact fees computed on allocated max-day demand rather than on meters or projected average gallons [1][2]. A prerequisite for all of these is disclosure: most operators publish only annual water totals, often aggregated across an entire corporate fleet, which conceals exactly the numbers — facility-level peak demand and load factor — that determine what the community must build [1].

KEY TAKEAWAY — Water systems are sized by the maximum day, not annual volume. Under purely volumetric rates and gallonage-based fees, every other ratepayer quietly finances a peaky customer’s capacity — and the number that would reveal it, facility-level peak demand, is the one operators rarely publish.

6. The Peak Does Not Disappear — It Migrates Among Three Networks

6.1 Water to electricity

There is a tempting policy response to the water problem: simply require waterless, all-dry cooling. Some operators in cool climates already do this voluntarily. But conservation of energy is unforgiving — the heat still has to leave the building, and if water may not carry it, electricity must. All-dry facilities need larger chillers and more fan power, and their cooling equipment works hardest, least efficiently, on the hottest afternoons — which is precisely the electric grid’s annual peak hour. Squeezing the water peak inflates the electric peak. Analysts now project that water availability will rival power availability as the binding constraint on data center siting within about five years, and warn that “unmet” water demand is too often counted as zero demand rather than as a constraint someone must eventually pay to relieve [1][3].

6.2 Electricity to natural gas

The migration does not stop at the electric meter. When a utility’s interconnection queue is measured in years, developers increasingly build their own power: on-site, “behind-the-meter” gas-fired generation. Industry analysis counts roughly 100 gigawatts of gas-burning capacity planned to power U.S. data centers [16]. At first glance this looks like the community’s problem solved — the data center pays for its own generation and spares electric ratepayers the capacity build-out. In reality it moves the peak to a third network that is sized, financed, and priced by exactly the same design-day logic as the other two.

Gas pipelines and distribution systems are built for their own worst day: the coldest winter morning, when every furnace and boiler runs at once. Capacity on that system is sold in two forms. Firm transportation is reserved and paid for every day of the year whether a single cubic foot flows — the purest expression of this paper’s unused-capacity economics, and the revenue stream that finances pipeline construction. Interruptible transportation is cheaper precisely because it is cut first when the system tightens [17]. A gas-fired data center plant is, like the facility it powers, admirably flat — a high-load-factor gas customer. But its winter demand lands squarely on the design day, stacked on top of heating customers, tightening capacity exactly when both sectors need it most; in pipeline-constrained regions, polar-vortex events already push gas systems to their limits [17][18]. If the data center buys firm capacity, it enlarges the design-day build-out someone must finance. If it economizes with interruptible service, its celebrated reliability quietly depends on diesel backup or on being curtailed — and if it under-contracts, the shortfall risk shifts to everyone else sharing the pipe. Add the local-acceptance problem — gas turbines bring emissions and noise that communities did not bargain for [15] — and the “bring your own power” model is revealed as the same arithmetic on a different network. And note what the water district reminds its member cities: on-site generation itself requires water — thermal plants need cooling too — so bringing your own power can also mean bringing additional water demand with it [22].

The lesson for communities is to evaluate a data center proposal as one interlocking peak-capacity problem across all three networks — water, electricity, and gas — because the developer’s cooling and power choices largely decide which system’s design day grows and, therefore, which set of ratepayers funds the standby capacity.

KEY TAKEAWAY — Deny water and the peak moves to the electric grid; deny grid power and it moves to the gas system’s worst winter morning — and the generators need water of their own. Evaluate all three networks as one decision.

7. Moratoriums, Municipal Credit, and the Pricing Alternative

The politics have begun to move faster than the rate design. At least eleven states have considered moratoriums on data center development; New York’s legislature has passed a Responsible Data Center Development Act imposing a one-year statewide pause — the nation’s first, if signed — while Maine’s legislature passed a similar measure that was vetoed by its governor, and individual municipalities have enacted their own local pauses [15]. Governors, legislatures, and regulators are now directly engaged: in Texas, the Public Utility Commission and the Texas Water Development Board are surveying existing and planned data centers on water use and treatment, with a PUC report due to the Legislative Budget Board and the Governor at the end of 2026 [22]. Communities that put their own terms in place now will negotiate ahead of the coming rulebook; those that wait will inherit whatever it says. Rating agencies, meanwhile, have supplied the underlying worry in careful language: substantially increased water and electricity demands “can strain existing infrastructure and require the build-out of new capacity,” and if those costs are not offset by new revenues, the community funds the difference to the detriment of its credit [15]. That sentence is this paper’s argument translated into credit analysis: the build-out is financed with decades of debt, while the offsetting revenue depends on rate structures that mostly track usage.

The credit risk compounds because peaky demand is also concentrated and cancelable demand. Industry tracking counts some 120 data center projects canceled since 2024, most of them recently and most due to local opposition [15]. A utility that issues thirty-year revenue bonds for maximum-day capacity sized to a single customer’s planned peak bears stranded-capacity risk three ways: the project may cancel before it draws a gallon, it may ramp to only a fraction of its reserved capacity (the contracted-versus-realized gap of Section 3.2), or the facility may be functionally obsolete in ten to fifteen years while the debt runs twice that long. A low load factor, high concentration, and cancelability is the worst available combination for a revenue bond. Seen this way, take-or-pay contracts, developer-funded infrastructure, and capacity charges that survive cancellation are not merely fairness measures — they are bondholder protection.

One bookkeeping discipline keeps the debate honest: fiscal losses are not utility losses. Texas is reported to forgo more than $1 billion per year in sales tax revenue through data center exemptions, and Virginia’s incentives have been estimated at similar annual magnitudes [15]. Those are tax expenditures — policy choices about revenue — and they belong in a different column from the capacity cost-shifting analyzed here. Conflating the two weakens both arguments and lets each be rebutted with answers to the other.

Industry’s standard defense, meanwhile, concedes the central point. The Data Center Coalition states its members expect to be billed their “full cost of service,” with no other ratepayer paying for costs “directly assigned” to them [15]. But costs are only directly assigned if the tariff assigns them. Under volumetric water rates and gallonage-based impact fees, a customer with a water load factor of 12 to 17 percent is — by construction, as Table 2 showed — subsidized by everyone else, however sincere its intentions. A moratorium, in the end, is a price-signal failure: it is what a community reaches for when its prices cannot yet say what its engineers already know. The constructive exit is the sequence this paper has argued throughout — an honest supply adequacy assessment first, then capacity-based pricing, ratchets, take-or-pay terms, and debt backstops. Operators who are committed, as the industry says, to being responsible neighbors can demonstrate it by signing.

KEY TAKEAWAY — A moratorium is a price-signal failure — what a community reaches for when its prices cannot yet say what its engineers already know. The durable fix: verify supply, then price capacity and write contracts that survive cancellation. Move before the state rulebook arrives.

8. The Other Side of the Ledger: Why a Community Might Want to Say Yes

8.1 The best possible shape of electric customer — with one condition

Everything in Section 3 deserves restating as a benefit, because it is one. An 80-to-100 percent load factor customer is the best possible shape of electric load: it buys enormous volumes of energy against the capacity reserved for it, spreading the utility’s fixed costs — poles, wires, substations, administration — across far more kilowatt-hours than any residential or commercial customer ever could. On a system with spare capacity, adding such a customer puts downward pressure on everyone else’s average rates. This is the classic load-factor-improvement argument that utilities themselves made for decades when courting industry, and data centers fit it better than almost any industrial load in history. Communities that reflexively treat a data center as a burden on the electric system have the shape of the problem backwards.

The condition is headroom. The fixed-cost-spreading logic works when the new load is absorbed by existing, underused capacity. When the load instead triggers new generation and transmission at today’s marginal costs — which now exceed embedded average costs in most regions — even a perfectly flat customer can raise average rates. The evidence is current: capacity prices in PJM, the nation’s largest grid market, jumped roughly nine-fold between the 2024/25 and 2025/26 auctions, the market monitor attributed 63 percent of that increase — about $9.3 billion in a single year — to data center demand growth, and residential bills in parts of the region rose $16 to $21 per month [20]. Neither story disproves the other: the same customer shape that lowers rates on a slack system raises them on a tight one. This is why the supply-and-headroom assessment of Section 2.4 must come first, and why the Duke flexibility finding matters so much — 76 gigawatts of room exists for loads willing to curtail a few hours a year [8]. The honest framing for a community is: a data center is the best-shaped electric customer available; whether it is also a rate-lowering one depends on the system it joins and on whether it pays the marginal cost of what must be built for it.

8.2 The fiscal engine: high taxable value, almost no service demand

The second benefit belongs to the tax assessor, not the utility. Decades of cost-of-community-services studies show that commercial and industrial property typically demands only 35 to 65 cents of local services for every dollar of revenue it generates, while residential development demands $1.15 to $1.50 — more than it pays [19]. A data center is an extreme version of the industrial case: enormous assessed value in buildings and equipment, combined with a few dozen to a hundred employees, no schoolchildren, negligible traffic, and minimal police and fire demand. The taxable value includes not just the real property but the business personal property — the servers themselves, often worth as much as the building — which is refreshed on a three-to-five-year cycle that keeps replenishing the tax base as older equipment depreciates.

Here the record needs one correction that strengthens the community’s hand. The widely cited Texas figure — more than $1 billion per year in forgone revenue — is a sales tax exemption on equipment purchases, a state-level policy choice [15]. Property tax is different: data centers generally owe it in full unless a local government chooses to abate it. That choice is the community’s single best bargaining chip, and it should be spent, not given away: an abatement worth tens of millions of dollars can be traded for precisely the protections this paper prescribes — capacity-based utility charges, take-or-pay terms, on-site peak mitigation, disclosure, and host-community payments.

But the fiscal case is not automatic, and honesty requires saying so: your mileage may vary — so measure it. Tax rates, abatement posture, school-district shares and recapture, utility ownership, debt structure, and siting jurisdiction all move the answer, sometimes decisively. In states like Texas, the school district share of property tax dominates the bill and recapture provisions export much of it beyond the community, so the locally retained benefit is smaller than the headline levy. A facility sited just outside city limits can burden a city-owned utility while paying the city nothing. And the jobs argument should be retired: construction employment is transitory and permanent staffing is small [15]; the durable benefits are fiscal and, under the right conditions, ratepayer relief — argue those instead. Because the arithmetic is so community-specific, the authors have built a companion interactive tool — the CityBase.Net Data Center Fiscal Impact Model — that walks a Texas city through the full 20-year calculation from the municipal government’s perspective: property and sales tax revenues, utility revenues and costs, municipal service costs, employment, capacity audit, and net fiscal impact under alternative scenarios [24]. The fundamental question the model asks is the right one: not “how big is the investment?” but “does the city collect more than it spends to serve the facility — and by how much?”

KEY TAKEAWAY — A data center can be the best-shaped utility customer a system has ever signed and a major tax base demanding almost nothing in services — where headroom exists and abatements are traded for protections, never given away. But every community’s numbers differ: run them. A companion fiscal model [24] exists for exactly that purpose.

9. Engineering Away the Water Peak: The On-Site Storage Option

The biggest technical objection in this paper — the collapsed water load factor — turns out to have a remarkably cheap fix, and understanding why it has not already happened everywhere is itself instructive. The fix is a tank: on-site storage that the data center fills slowly from the public system at a contractually capped rate, around the clock and across the seasons, and draws down during heat waves. The tank does for the water system exactly what a battery does for the grid — it converts a peaky customer into a flat one. Nor is it an alien imposition: high-reliability facilities already keep hours of cooling water on-site as standard practice for ride-through of utility interruptions [12]; the proposal here simply extends hours to days.

The arithmetic is worth showing. Consider an illustrative 100 MW facility using dry cooling with evaporative assist. At a planned peak water intensity of 1.15 liters per kilowatt-hour — the Leesburg planning figure [1] — its peak-day demand is about 0.73 MGD, while at a 12 percent water load factor its average day is roughly 0.09 MGD. Table 4 shows what a tank does to the capacity the public system must reserve.

Contract designMax draw from utilityTank size (7-day design heat wave)Illustrative tank cost
No cap (status quo)0.73 MGDNone$0 — but the utility builds 0.73 MGD of capacity
Partial cap0.25 MGD≈ 3.4 million gallons≈ $7–14 million
Near-flat (≈100% water load factor)0.10 MGD≈ 4.4 MG (≈6.3 MG for a 10-day event)≈ $9–18 million

Table 4. Illustrative on-site storage sizing for a 100 MW data center with dry cooling and evaporative assist (peak day ≈0.73 MGD at 1.15 L/kWh [1]; average day ≈0.09 MGD at a 12% water load factor). Tank costs assume roughly $2–4 per gallon installed for multi-million-gallon ground storage [21]. All figures are order-of-magnitude planning estimates.

Three things stand out. First, full flattening costs barely more than partial mitigation — once the tank is sized for a design heat wave, capping the utility draw near the average adds little. Second, the money is small where it matters: $9 to $18 million is on the order of one percent of the capital cost of a 100 MW facility, and it is comparable to the utility-side capacity it avoids — in the Indiana case, new supply capacity is being built at roughly $22 per gallon-per-day, so the 0.6 MGD this tank avoids would cost the public system a similar $14 million [1]. The difference is who finances it and where it sits: private capital on private land, with no six-year municipal construction timeline and no revenue bond at risk. Third, a five-million-gallon ground tank is roughly 130 feet in diameter — a rounding error on a data center campus.

Why, then, are such tanks rare? Because under volumetric rates nobody has a reason to build one: the utility bears the peak, and the data center pays only for gallons. The academic literature observes that operators rarely rely on storage for multi-day peaks and attributes this to cost [1] — but the cost is modest; what is missing is the price signal. Charge for allocated maximum-day capacity, or cap the maximum draw in the service agreement, and the tank becomes the developer’s own cheapest solution. On-site storage is thus the clearest illustration of this paper’s thesis: correct pricing does not merely allocate the cost of the peak fairly — it causes the peak to be engineered away by the party best positioned to do it.

The honest caveats: the tank must be sized to the drought-of-record heat wave duration, not an average one; potable storage requires active turnover and disinfection management; the cap must be enforceable — metered, telemetered, with penalty ratchets, not aspirational; fire flow remains a separate requirement; and storage shaves the delivery peak without reducing consumption, so it solves nothing in a genuine supply shortage — the Section 2.4 assessment still comes first. None of these caveats changes the conclusion; they define the contract terms. The companion fiscal model’s capacity-audit and water-utility modules can be used to test these terms against a specific proposal [24].

KEY TAKEAWAY — For roughly one percent of project cost, on-site storage turns the peakiest water customer a system has ever seen into a flat one. Tanks are rare only because volumetric rates give nobody a reason to build them. Price the peak, and the developer builds the tank.

10. Conclusion: Not “No” — “Yes, If”

A community is rarely overwhelmed by the gallons or kilowatt-hours a data center consumes in a year — provided the supply exists. It is overwhelmed by the size of the pipe, the plant, and the wire that must stand ready for the worst afternoon of the summer — capacity that is financed every day of the year and used only on a few. The single most informative number in any data center proposal is therefore its load factor: average demand divided by peak demand — in other words, how much of the capacity reserved for the customer is actually used. It is also, not coincidentally, the number operators disclose least.

The full ledger, honestly stated, looks like this. On the benefit side: the best-shaped electric customer utilities have ever been offered, capable of putting downward pressure on everyone’s rates where headroom exists; and a fiscal engine — enormous taxable value demanding almost nothing in services — whose abatement is a bargaining chip the community controls. On the cost side: water load factors of 3 to 17 percent landing on heat-wave design days; wastewater with concentrated chemistry and its own peak; reserved-but-unused electric capacity; second-scale power transients; winter gas design-day exposure; and thirty-year debt issued against a customer that may cancel, under-ramp, or be obsolete in fifteen. The decisive fact is that every entry on the cost side has a known mitigating instrument. These are not exotic inventions; they are the standard toolbox of utility contracting, applied to a new customer class. The productive posture for a community is neither “no” nor an unexamined “yes,” but “yes, if” — and the “if” is a term sheet, not a sentiment:

  • Verify supply first, under stress conditions — drought of record, heat wave, polar vortex — for water, power, and gas together. If supply fails, the conversation is evenhanded curtailment for all users, not a ban on one industry.
  • Price capacity, not just volume: charges based on allocated maximum-day and coincident-peak demand, with ratchets so a customer who sets a peak keeps paying for it.
  • Contract the mitigation, don’t request it: on-site storage or a telemetered max-day cap with penalties for the water peak; minimum takes for reserved electric capacity; on-site batteries for transients; firm gas transportation assigned to any on-site generation; pretreatment terms for the wastewater.
  • Protect the debt: take-or-pay terms, term-matched financing, and developer-funded infrastructure that survive cancellation, under-ramping, and obsolescence.
  • Trade abatements for protections — never grant both. The property tax base is the community’s leverage; spend it deliberately.
  • Require disclosure as a condition of service: facility-level peak demand and load factor, published — because the political stumbling block is trust, and trust follows from terms the public can read.

A community that does this converts the peakiest water customer it has ever seen into a flat one, converts stranded-debt risk into developer capital, and keeps the two benefits — the ratepayer arithmetic and the tax base — that made the project attractive in the first place. A moratorium is what a community reaches for when its prices cannot yet say what its engineers already know. Utilities do not go broke selling water. They go broke building for water they rarely sell — and peaks, not totals, are what force them to build. Price the peak, contract the cure, and the right answer to a well-sited data center is yes.

References

[1] “Small Bottle, Big Pipe: Quantifying and Addressing the Impact of Data Centers on Public Water Systems,” arXiv preprint 2603.02705 (2026). Primary source for water peaking data, case studies (The Dalles, West Des Moines, Leesburg, Prince William, Indiana, Wisconsin), capacity valuations, and infrastructure cost figures. Reports daily peaking factors; converted to load factors in this paper (load factor = 1 ÷ peaking factor). https://arxiv.org/abs/2603.02705

[2] Norris, T., “The Puzzle of Low Data Center Utilization Rates,” Power & Policy, August 7, 2025. Distinctions among load factor, capacity utilization, and uptime; survey of industry load-factor assumptions. https://www.powerpolicy.net/p/the-puzzle-of-low-data-center-utilization

[3] Energy and Environmental Economics (E3), “Forecasting Large Loads in the Age of AI and Data Centers,” whitepaper, December 2025. Utility planning load factors (Duke ≈80%, Dominion ≈82%) and metered load-factor findings. https://www.ethree.com/wp-content/uploads/2025/12/E3Whitepaper_DataCenterForecasting.pdf

[4] “Electricity Demand and Grid Impacts of AI Data Centers: Challenges and Prospects,” arXiv preprint 2509.07218 (2025). Reports peak-to-average ratios of ≈1.0 for AI training and 1.5–2.0 for conventional data centers — equivalent to load factors of ≈100% and 50–65% respectively; transient characteristics. https://arxiv.org/html/2509.07218v3

[5] “Technical Challenges of AI Data Center Integration into Power Grids — A Survey,” Energies 19(1):137 (2026). Gradient-synchronization power oscillations and megawatt-per-second ramp rates. https://www.mdpi.com/1996-1073/19/1/137

[6] “Power Stabilization for AI Training Datacenters,” arXiv preprint 2508.14318 (2025). Facility-scale power swing magnitudes and mitigation approaches. https://arxiv.org/html/2508.14318v1

[7] SemiAnalysis, “AI Training Load Fluctuations at Gigawatt-scale — Risk of Power Grid Blackout?” (2025). https://newsletter.semianalysis.com/p/ai-training-load-fluctuations-at-gigawatt-scale-risk-of-power-grid-blackout

[8] Norris, T., et al., “Rethinking Load Growth: Assessing the Potential for Integration of Large Flexible Loads in US Power Systems,” Nicholas Institute for Energy, Environment & Sustainability, Duke University (2025). 76 GW headroom at 0.25% annual curtailment (≈85 hours/year). Summary coverage: Utility Dive. https://www.utilitydive.com/news/us-grid-headroom-flexible-load-data-center-ai-ev-duke-report/739767/

[9] West Des Moines Water Works, monthly financial reports, 2022–2025 (monthly withdrawal data for the West Des Moines hyperscale facility and comparison of large-user demand patterns), as compiled and analyzed in [1].

[10] Prince William Water service-area analysis (measured daily data center water load factor of 10% in 2024; Northern Virginia weighted actual water load factor of 27–29%), as cited in [1].

[11] U.S. Environmental Protection Agency, Drinking Water Infrastructure Needs Survey and Assessment; Clean Watersheds Needs Survey; and 2024 Report to Congress on water affordability (national funding needs of $1.3T+ over 20 years; 12.1–19.2 million households lacking affordable water service), as cited in [1].

[12] DgtlInfra, “Data Center Water Usage: A Comprehensive Guide.” Cooling system mechanics, evaporation, blowdown, cycles of concentration, and on-site water storage for reliability. https://dgtlinfra.com/data-center-water-usage/

[13] Vantage Data Centers, “Cooling Without the Drain: How Closed-Loop Systems Cut Day-to-Day Water Use” (2026). https://blog.vantage-dc.com/2026/04/22/cooling-without-the-drain-how-closed-loop-systems-cut-day-to-day-water-use/

[14] Shehabi, A., et al., “2024 United States Data Center Energy Usage Report,” Lawrence Berkeley National Laboratory, LBNL-2001637 (2024). Utilization data gaps and transparency needs. https://eta.lbl.gov/publications/2024-lbnl-data-center-energy-usage-report

[15] Royal, C., “More states are considering putting a pause on data centers,” The Bond Buyer, July 8, 2026. State and local moratoriums; Moody’s and S&P analyst commentary; 120 canceled projects (S&P 451 Research); Texas and Virginia tax-incentive figures; Data Center Coalition statements. https://www.bondbuyer.com

[16] Institute for Energy Research, “Natural Gas is Preferred by Data Centers and Manufacturers, and More Capacity and Pipelines are Needed” (2026), citing BloombergNEF analysis of ~100 GW of planned on-site gas-fired capacity for U.S. data centers. https://www.instituteforenergyresearch.org/fossil-fuels/natural-gas-is-preferred-by-data-centers-and-manufacturers-and-more-capacity-and-pipelines-are-needed/

[17] American Oil & Gas Reporter, “Ramping Data Center Demand Prompts Improved Coordination Between Gas, Electric Sectors.” Firm versus interruptible transportation; winter coincidence of data center and heating loads. https://www.aogr.com/magazine/markets-analytics/ramping-data-center-demand-prompts-improved-coordination-between-gas-electric-sectors

[18] Utility Dive, “Behind-the-meter data center gas plants will raise US energy bills” (2026). Pipeline-capacity effects of behind-the-meter data center generation. https://www.utilitydive.com/news/data-centers-raise-energy-bills-not-for-reason-you-think/822205/

[19] American Farmland Trust / Farmland Information Center, “Cost of Community Services Studies” (fact sheet summarizing 150+ studies): commercial/industrial land typically requires $0.35–$0.65 of local services per $1.00 of revenue generated; residential requires $1.15–$1.50. https://farmlandinfo.org/publications/cost-of-community-services-studies/

[20] Institute for Energy Economics and Financial Analysis (IEEFA), “Projected data center growth spurs PJM capacity prices” (2025), and Office of the People’s Counsel (D.C.) / Synapse Energy Economics, “Drivers of PJM’s Capacity Market Price Surge” (2025). Capacity prices rose from $28.92/MW-day (2024/25) to $269.92 (2025/26) and $329.17 (2026/27); Monitoring Analytics attributes 63% of the 2025/26 increase (≈$9.3B) to data centers; residential impacts of $16–21/month in parts of the region. https://ieefa.org/resources/projected-data-center-growth-spurs-pjm-capacity-prices-factor-10

[21] Vendor and industry cost guides for large ground-level water storage (welded steel, bolted steel, and prestressed concrete tanks to 5+ million gallons), indicating roughly $2–4 per gallon installed at multi-million-gallon scale (site-specific). https://www.tank-depot.com/blog/water-tank-prices-how-much-does-a-water-tank-cost

[22] North Texas Municipal Water District, “Facts About Data Centers: Considerations for NTMWD Member Cities and Customers” (2026). Texas data center counts and regional distribution; water and electricity use figures; cooling-system water guidance; wastewater chemistry (biocides, corrosion inhibitors, phosphates, nitrites, heavy metals; high-TDS blowdown); guidance to engage District planning and pretreatment teams early; PUC/TWDB surveys and end-of-2026 report to the Legislative Budget Board and Governor. https://www.ntmwd.com

[23] Cook, M., “Thirsty Data and the Lone Star State: The Impact of Data Center Growth on Texas’ Water Supply,” Houston Advanced Research Center (January 2026). Texas data centers used ≈25 billion gallons in 2025; projected 29–161 billion gallons annually by 2030 (up to ≈2.7% of state water use); 400+ facilities; ≈9,500 MW today with ERCOT 2030 forecasts of ≈22,000–78,000 MW; notes ERCOT has a large-load interconnection process while no parallel statewide water-planning process exists. https://harcresearch.org/research/thirsty-data-and-the-lone-star-state-the-impact-of-data-center-growth-on-texas-water-supply/

[24] McLain, L., et al., “Data Center Fiscal Impact Model — Municipal Revenue & Cost Analysis Tool for Texas Cities,” CityBase.Net, Interactive Model v1.0 (2026). Twenty-year net fiscal impact from the municipal perspective: property and sales tax, utility revenues and costs, power demand, employment, municipal service costs, capacity audit, scenarios, and case studies. https://datacenterfiscalimpact.netlify.app/

The Infrastructure We Don’t See: Aging Gas Systems, Hidden Risks, and the Case for Annual Accountability

A collaboration between Lewis McLain & AI

It’s not if, but when!

Natural gas infrastructure is the most invisible—and therefore the most misunderstood—critical system in modern cities. Power lines are visible. Water mains announce themselves through pressure and flow. Roads crack and bridges age in plain sight. But gas lines remain buried, silent, and largely forgotten—until something goes wrong.

That invisibility is not benign. It creates a governance gap where responsibility is fragmented, risk is assumed rather than measured, and accountability is episodic instead of continuous. As cities grow denser, older, and more complex, that gap widens.

This essay makes a simple but demanding case: cities should require annual, technical accountability briefings from gas utilities and structured gas-safety evaluations for high-occupancy buildings—public and private—because safety is no longer assured by age, ownership boundaries, or regulatory compliance alone.

The ultimate question is not whether gas systems are regulated. They are.
The question is whether, at the local level, we are actually safer than we were a year ago.


I. The Aging Gas Network: A Technical Reality, Not a Hypothetical

Much of the U.S. gas distribution network was installed decades ago. While significant modernization has occurred, legacy materials—particularly cast iron and bare steel—still exist in pockets, often in the very neighborhoods where density, redevelopment, and consequence are highest.

These systems age in predictable ways:

  • Material degradation such as corrosion, joint failure, and metal fatigue
  • Ground movement from expansive soils, drought cycles, and freeze–thaw conditions
  • Pressure cycling driven by modern load variability
  • Construction interaction, including third-party damage during roadway, utility, and redevelopment projects

Technically speaking, aging is not a binary condition. It is a curve. Systems do not fail all at once; they fail where stress, material fatigue, and external disturbance intersect. Cities that approve redevelopment without understanding where those intersections lie are not managing risk—they are inheriting it.


II. Monitoring Is Better Than Ever—But It Is Not Replacement

Modern gas utilities deploy advanced leak detection technologies that did not exist a generation ago: mobile survey vehicles, high-sensitivity handheld sensors, aerial detection, and in some cases continuous monitoring.

Regulatory standards have improved as well. Leak surveys are more frequent, detection thresholds are lower, and repair timelines are clearer. From a technical standpoint, the industry is better at finding leaks than it was even a few years ago.

But monitoring is inherently reactive. It detects deterioration after it has begun. It does not restore structural integrity. It does not change the age profile of the system. It does not eliminate brittle joints or corrosion-prone materials.

Replacement is the only permanent risk reduction. And replacement is expensive, disruptive, and largely invisible unless cities require it to be discussed openly.


III. Why Annual Gas Utility Accountability Briefings Are Essential

Gas utilities operate under long-range capital replacement programs driven by regulatory approval, rate recovery, and internal prioritization models. Cities operate under land-use approvals, zoning changes, density increases, and redevelopment pressures that can change risk far faster than infrastructure plans adjust.

An annual gas utility accountability briefing is how those two worlds reconnect.

Not a promotional update. Not a general safety overview. But a technical, decision-grade briefing that allows city leadership to understand:

  • What materials remain in the ground
  • Where risk is concentrated
  • How fast legacy systems are being retired
  • Whether replacement is keeping pace with growth
  • Where development decisions may be increasing consequence

Without this, cities are effectively approving new intensity above ground while assuming adequacy below it.


IV. The Forgotten Segment: From the Meter to the Building

Most gas incidents that injure people do not originate in transmission pipelines or deep mains. They occur closest to occupied space—often in the short stretch between the gas meter and the building structure.

Legally, responsibility is clear:

  • The utility owns and maintains the system up to the meter.
  • The property owner owns everything downstream.

Assessment, however, is not.

Post-meter gas piping is frequently:

  • Older steel without modern corrosion protection
  • Stressed by foundation movement
  • Altered during remodels and additions
  • Poorly documented
  • Rarely inspected after initial construction

Utilities generally do not inspect customer-owned piping. Building departments see it only during permitted work. Fire departments respond after leaks are reported. Property owners often do not realize they own it.

This creates a true orphaned asset class: high-consequence infrastructure with no lifecycle oversight.


V. Responsibility Alone Is Not Safety

Cities often take comfort in the legal distinction: “That’s private property.” Legally, that is correct. Practically, it is insufficient.

Gas does not respect ownership boundaries. A failure inside a school, apartment building, restaurant, or nursing home becomes a public emergency immediately.

Risk governance does not require cities to assume liability. It requires them to ensure that someone is actually evaluating risk in places where failure would have severe consequences.


VI. Required Gas-Safety Evaluations for High-Occupancy Properties

This is the missing pillar of modern gas safety.

Just as elevators, fire suppression systems, and boilers undergo periodic inspection, gas piping systems in high-occupancy buildings should be subject to structured evaluation—regardless of whether the building is publicly or privately owned.

Facilities warranting mandatory evaluation include:

  • Schools (public and private)
  • Daycares
  • Nursing homes and assisted-living facilities
  • Hospitals and clinics
  • Large multifamily buildings
  • Assembly venues (churches, theaters, gyms)
  • Restaurants and food-service establishments
  • High-load commercial and industrial users

These are places where evacuation is difficult, ignition sources are common, and consequences are magnified.

A gas-safety evaluation should assess:

  • Condition and material of post-meter piping
  • Corrosion, support, and anchoring
  • Stress at building entry points
  • Evidence of undocumented modifications or abandoned lines
  • Accessibility and labeling of shutoff valves

These evaluations need not be frequent. They need to be periodic, triggered, and credible.


VII. Triggers That Make the System Work

Cities can implement this framework without blanket inspections by tying evaluations to specific events:

  • Change of occupancy or use
  • Major remodels or additions
  • Buildings reaching certain age thresholds when work is permitted
  • Repeated gas odor or leak responses
  • Sale or transfer of high-occupancy properties

This approach focuses effort where risk is most likely to have changed.


VIII. Public vs. Private: One Standard of Care

A gas explosion in a public school is not meaningfully different from one in a private daycare or restaurant. The victims do not care who owned the pipe.

A city that limits safety evaluation requirements to public buildings is acknowledging risk—but only partially. The standard should be risk-based, not ownership-based.


IX. Are We Better or Worse Off Than a Year Ago?

Technically, the answer is nuanced.

We are better off nationally in detection capability and regulatory clarity. Technology has improved. Survey frequency has increased. Reporting is stronger.

But many cities are likely worse off locally in exposure:

  • Buildings are older
  • Density is higher
  • Construction activity is heavier
  • Post-meter piping remains largely unassessed
  • High-occupancy facilities rely on outdated assumptions

So the honest answer is this:

We are better at finding problems—but not necessarily better at eliminating risk where people live, work, and gather.


X. Governance Is the Missing Link

Gas safety is no longer only an engineering problem. It is a governance problem.

Cities already regulate:

  • Land use and density
  • Building permits and occupancy
  • Business licensing
  • Emergency response coordination

Requiring annual gas utility accountability briefings and targeted gas-safety evaluations does not expand government arbitrarily. It closes a blind spot that modern urban conditions have exposed.


Conclusion: Asking the Right Question, Every Year

The most important question cities should ask annually is not:

“Did the utility comply with regulations?”

It is:

“Given our growth, our buildings, and our infrastructure, are we actually safer than we were last year?”

If city leaders cannot answer that clearly—above ground and below—it is not because the answer is unknowable.

It is because no one has required it to be known.


**Appendix A

Model Ordinance: Gas Infrastructure Accountability and High-Occupancy Safety Evaluations**

This model ordinance is designed to improve transparency, situational awareness, and public safety without transferring ownership, operational control, or liability from utilities or property owners to the City.


Section 1. Purpose and Findings

1.1 Purpose

The purpose of this ordinance is to:

  1. Improve transparency regarding the condition, monitoring, and replacement of gas infrastructure;
  2. Ensure that risks associated with aging gas systems are identified and reduced over time;
  3. Require periodic gas safety evaluations for high-occupancy buildings where consequences of failure are greatest;
  4. Strengthen coordination among gas utilities, property owners, and City emergency services; and
  5. Establish consistent, decision-grade information for City leadership.

1.2 Findings

The City Council finds that:

  1. Natural gas infrastructure is largely underground and not visible to the public.
  2. Portions of the gas system—including customer-owned piping—may age without systematic reassessment.
  3. Increased density, redevelopment, and construction activity elevate the consequences of gas failures.
  4. Existing regulatory frameworks do not provide city-specific visibility into system condition or replacement progress.
  5. Periodic reporting and targeted evaluation improve public safety without assuming utility or private ownership responsibilities.

Section 2. Annual Gas Utility Accountability Briefing

2.1 Requirement

Each gas utility operating within the City shall provide an Annual Gas Infrastructure Accountability Briefing to the City Council or its designated committee.

2.2 Scope

The briefing shall address, at a minimum:

  • Pipeline materials and age profile;
  • Replacement progress and future plans;
  • Leak detection, classification, and repair performance;
  • High-consequence areas and impacts of development;
  • Construction coordination and damage prevention;
  • Emergency response readiness and communication protocols.

2.3 Format and Standards

  • Briefings shall include written materials, maps, and data tables.
  • Metrics shall be presented in a year-over-year comparable format.
  • Information shall be technical, factual, and suitable for governance decision-making.

2.4 No Transfer of Liability

Nothing in this section shall be construed to transfer ownership, maintenance responsibility, or operational control of gas facilities to the City.


Section 3. High-Occupancy Gas Safety Evaluations

3.1 Covered Facilities

Gas safety evaluations are required for the following facilities, whether publicly or privately owned:

  • Schools (public and private)
  • Daycare facilities
  • Nursing homes and assisted-living facilities
  • Hospitals and medical clinics
  • Multifamily buildings exceeding [X] dwelling units
  • Assembly occupancies exceeding [X] persons
  • Restaurants and commercial food-service establishments
  • Other facilities designated by the Fire Marshal as high-consequence occupancies

3.2 Scope of Evaluation

Evaluations shall assess:

  • Condition and materials of post-meter gas piping
  • Corrosion potential and structural support
  • Stress at building entry points and foundations
  • Evidence of undocumented modifications or abandoned piping
  • Accessibility, labeling, and operation of shutoff valves

3.3 Qualified Evaluators

Evaluations shall be conducted by:

  • Licensed plumbers,
  • Licensed mechanical contractors, or
  • Professional engineers with gas system experience.

3.4 Triggers

Evaluations shall be required upon:

  • Change of occupancy or use;
  • Major remodels or building additions;
  • Buildings reaching [X] years of age when permits are issued;
  • Repeated gas odor complaints or leak responses;
  • Sale or transfer of covered properties, if adopted by the City.

Section 4. Documentation and Compliance

4.1 Certification

Property owners shall submit documentation certifying completion of required evaluations.

4.2 Corrective Action

Identified hazards shall be corrected within timeframes established by code officials.

4.3 Enforcement

Non-compliance may result in:

  • Withholding of permits or certificates of occupancy;
  • Temporary suspension of approvals;
  • Administrative penalties as authorized by law.

Section 5. Education and Coordination

The City shall:

  • Provide educational materials clarifying ownership and safety responsibilities;
  • Coordinate with gas utilities on public outreach;
  • Integrate findings into emergency response planning and training.


**Appendix B

Annual Gas Utility Accountability Briefing — Preparation Checklist**

This checklist ensures annual briefings are consistent, measurable, and focused on risk reduction rather than general compliance.


I. System Inventory & Condition

☐ Total pipeline miles within city limits (distribution vs. transmission)
☐ Pipeline miles by material type
☐ Pipeline miles by decade installed
☐ Location and extent of remaining legacy materials
☐ Identification of oldest segments still in service


II. Replacement Progress

☐ Miles replaced in the previous year (by material type)
☐ Five-year replacement plan with schedules
☐ Funded vs. unfunded replacement projects
☐ Year-over-year reduction in legacy materials
☐ Explanation of changes from prior plans


III. Leak Detection & Repair Performance

☐ Total leaks detected (normalized per mile)
☐ Leak classification breakdown
☐ Average and maximum repair times by class
☐ Repeat leak locations identified and mapped
☐ Root-cause analysis of recurring issues


IV. Monitoring Technology

☐ Detection technologies currently deployed
☐ Survey frequency achieved vs. required
☐ Use of advanced or emerging detection tools
☐ Known limitations of monitoring methods


V. High-Consequence Areas

☐ Definition and criteria for high-consequence zones
☐ Updated risk maps
☐ Impact of new development on risk profile
☐ Trunk lines serving rapidly densifying areas


VI. Construction & Damage Prevention

☐ Third-party damage incidents
☐ 811 ticket response performance
☐ High-risk project types identified
☐ Coordination procedures with City capital projects


VII. Emergency Response Readiness

☐ Incident response timelines
☐ Coordination with fire, police, and emergency management
☐ Date and scope of last joint exercise or drill
☐ Public communication and notification protocols


VIII. Customer-Owned (Post-Meter) Piping

☐ Incidents involving post-meter piping
☐ Common failure materials or conditions
☐ Customer education and outreach efforts
☐ Voluntary inspection or assistance programs


IX. Forward-Looking Risk Assessment

☐ Top unresolved risks
☐ Areas of greatest concern
☐ Commitments for the next 12 months
☐ Clear answer to:
“Are we safer than last year—and why?”


Closing Note

A briefing that cannot complete this checklist is not incomplete—it is revealing where risk remains unmanaged.

That visibility is the purpose of accountability.

Population as the Primary and Predictable Driver of Local Government Forecasting

A collaboration between Lewis McLain & AI

A technical framework for staffing, facilities, and cost projection

Abstract

In local government forecasting, population is the dominant driver of service demand, staffing requirements, facility needs, and operating costs. While no municipal system can be forecast with perfect precision, population-based models—when properly structured—produce estimates that are sufficiently accurate for planning, budgeting, and capital decision-making. Crucially, population growth in cities is not a sudden or unknowable event.

Through annexation, zoning, platting, infrastructure construction, utility connections, and certificates of occupancy, population arrival is observable months or years in advance. This paper presents population not merely as a driver, but as a leading indicator, and demonstrates how cities can convert development approvals into staged population forecasts that support rational staffing, facility sizing, capital investment, and operating cost projections.


1. Introduction: Why population sits at the center

Local governments exist to provide services to people. Police protection, fire response, streets, parks, water, sanitation, administration, and regulatory oversight are all mechanisms for supporting a resident population and the activity it generates. While policy choices and service standards influence how services are delivered, the volume of demand originates with population.

Practitioners often summarize this reality informally:

“Tell me the population, and I can tell you roughly how many police officers you need.
If I know the staff, I can estimate the size of the building.
If I know the size, I can estimate the construction cost.
If I know the size, I can estimate the electricity bill.”

This paper formalizes that intuition into a defensible forecasting framework and addresses a critical objection: population is often treated as uncertain or unknowable. In practice, population growth in cities is neither sudden nor mysterious—it is permitted into existence through public processes that unfold over years.


2. Population as a base driver, not a single-variable shortcut

Population does not explain every budget line, but it explains most recurring demand when paired with a small number of modifiers.

At its core, many municipal services follow this structure:

Total Demand=α+β⋅Population

Where:

  • α (fixed minimum) represents baseline capacity required regardless of size (minimum staffing, governance, 24/7 coverage).
  • β (variable component) represents incremental demand generated by each additional resident.

This structure explains why:

  • Small cities appear “overstaffed” per capita (fixed minimum dominates).
  • Mid-sized and large cities stabilize into predictable staffing ratios.
  • Growth pressures emerge when population increases faster than capacity adjustments.

Population therefore functions as the load variable of local government, analogous to demand in utility planning.


3. Why population reliably predicts service demand

3.1 People generate transactions

Residents generate:

  • Calls for service
  • Utility usage
  • Permits and inspections
  • Court activity
  • Recreation participation
  • Library circulation
  • Administrative transactions (HR, payroll, finance, IT)

While individual events vary, aggregate demand scales with population.

3.2 Capacity, not consumption, drives budgets

Municipal budgets fund capacity, not just usage:

  • Staff must be available before calls occur
  • Facilities must exist before staff are hired
  • Vehicles and equipment must be in place before service delivery

Capacity decisions are inherently population-driven.


4. Population growth is observable before it arrives

A defining feature of local government forecasting—often underappreciated—is that population growth is authorized through public approvals long before residents appear in census or utility data.

Population does not “arrive”; it progresses through a pipeline.


5. The development pipeline as a population forecasting timeline

5.1 Annexation: strategic intent (years out)

Annexation establishes:

  • Jurisdictional responsibility
  • Long-term service obligations
  • Future land-use authority

While annexation does not create immediate population, it signals where population will eventually be allowed.

Forecast role:

  • Long-range horizon marker
  • Infrastructure and service envelope planning
  • Typical lead time: 3–10 years

5.2 Zoning: maximum theoretical population

Zoning converts land into entitled density.

From zoning alone, cities can estimate:

  • Maximum dwelling units
  • Maximum population at buildout
  • Long-run service ceilings

Zoning defines upper bounds, even if timing is uncertain.

Forecast role:

  • Long-range capacity planning
  • Useful for master plans and utility sizing
  • Typical lead time: 3–7 years

5.3 Preliminary plat: credible development intent

Preliminary plat approval signals:

  • Developer capital commitment
  • Defined lot counts
  • Identified phasing

Population estimates become quantifiable, even if delivery timing varies.

Forecast role:

  • Medium-high certainty population
  • First stage for phased population modeling
  • Typical lead time: 1–3 years

5.4 Final plat: scheduled population

Final plat approval:

  • Legally creates lots
  • Locks in density and configuration
  • Triggers infrastructure construction
  • Impact Fees & other costs are committed

At this point, population arrival is no longer speculative.

Forecast role:

  • High-confidence population forecasting
  • Suitable for annual budget and staffing models
  • Typical lead time: 6–24 months

5.5 Infrastructure construction: timing constraints

Once streets, utilities, and drainage are built, population arrival becomes physically constrained by construction schedules.

Forecast role:

  • Narrow timing window
  • Supports staffing lead-time decisions
  • Typical lead time: 6–18 months

5.6 Water meter connections: imminent occupancy

Water meters are one of the most reliable near-term indicators:

  • Each residential meter ≈ one household
  • Installations closely precede vertical construction

Forecast role:

  • Quarterly or monthly population forecasting
  • Just-in-time operational scaling
  • Typical lead time: 1–6 months

5.7 Certificates of Occupancy: population realized

Certificates of occupancy convert permitted population into actual population.

At this point:

  • Service demand begins immediately
  • Utility consumption appears
  • Forecasts can be validated

Forecast role:

  • Confirmation and calibration
  • Not prediction

6. Population forecasting as a confidence ladder

Development StagePopulation CertaintyTiming PrecisionPlanning Use
AnnexationLowVery lowStrategic
ZoningLow–MediumLowCapacity envelopes
Preliminary PlatMediumMediumPhased planning
Final PlatHighMedium–HighBudget & staffing
Infrastructure BuiltVery HighHighOperational prep
Water MetersExtremely HighVery HighNear-term ops
COsCertainExactValidation

Population forecasting in cities is therefore graduated, not binary.


7. From population to staffing

Once population arrival is staged, staffing can be forecast using service-specific ratios and fixed minimums.

7.1 Police example (illustrative ranges)

Sworn officers per 1,000 residents commonly stabilize within broad bands depending on service level and demand, also tied to known local ratios:

  • Lower demand: ~1.2–1.8
  • Moderate demand: ~1.8–2.4
  • High demand: ~2.4–3.5+

Civilian support staff often scale as a fraction of sworn staffing.

The appropriate structure is:Officers=αpolice+βpolicePopulationOfficers = \alpha_{police} + \beta_{police} \cdot PopulationOfficers=αpolice​+βpolice​⋅Population

Where α accounts for minimum 24/7 coverage and supervision.


7.2 General government staffing

Administrative staffing scales with:

  • Population
  • Number of employees
  • Asset inventory
  • Transaction volume

A fixed core plus incremental per-capita growth captures this reality more accurately than pure ratios.


8. From staffing to facilities

Facilities are a function of:

  • Headcount
  • Service configuration
  • Security and public access needs

A practical planning method:Facility Size=FTEGross SF per FTEFacility\ Size = FTE \cdot Gross\ SF\ per\ FTEFacility Size=FTE⋅Gross SF per FTE

Typical blended civic office planning ranges usually fall within:

  • ~175–300 gross SF per employee

Specialized spaces (dispatch, evidence, fleet, courts) are layered on separately.


9. From facilities to capital and operating costs

9.1 Capital costs

Capital expansion costs are typically modeled as:Capex=Added SFCost per SF(1+Soft Costs)Capex = Added\ SF \cdot Cost\ per\ SF \cdot (1 + Soft\ Costs)Capex=Added SF⋅Cost per SF⋅(1+Soft Costs)

Where soft costs include design, permitting, contingencies, and escalation.


9.2 Operating costs

Facility operating costs scale predictably with size:

  • Electricity: kWh per SF per year
  • Maintenance: % of replacement value or $/SF
  • Custodial: $/SF
  • Lifecycle renewals

Electricity alone can be reasonably estimated as:Annual Cost=SFkWh/SF$/kWhAnnual\ Cost = SF \cdot kWh/SF \cdot \$/kWhAnnual Cost=SF⋅kWh/SF⋅$/kWh

This is rarely exact—but it is directionally reliable.


10. Key modifiers that refine population models

Population alone is powerful but incomplete. High-quality forecasts adjust for:

  • Density and land use
  • Daytime population and employment
  • Demographics
  • Service standards
  • Productivity and technology
  • Geographic scale (lane miles, acres)

These modifiers refine, but do not replace, population as the base driver.


11. Why growth surprises cities anyway

When cities claim growth was “unexpected,” the issue is rarely lack of information. More often:

  • Development signals were not integrated into finance models
  • Staffing and capital planning lagged approvals
  • Fixed minimums were ignored
  • Threshold effects (new stations, expansions) were deferred too long

Growth that appears sudden is usually forecastable growth that was not operationalized.


12. Conclusion

Population is the primary driver of local government demand, but more importantly, it is a predictable driver. Through annexation, zoning, platting, infrastructure construction, utility connections, and certificates of occupancy, cities possess a multi-year advance view of population arrival.

This makes it possible to:

  • Phase staffing rationally
  • Time facilities before overload
  • Align capital investment with demand
  • Improve credibility with councils, auditors, and rating agencies

In local government, population growth is not a surprise. It is a permitted, engineered, and scheduled outcome of public decisions. A forecasting system that treats population as both a driver and a leading indicator is not speculative—it is simply paying attention to the city’s own approvals.


Appendix A

Defensibility of Population-Driven Forecasting Models

A response framework for auditors, rating agencies, and governing bodies

Purpose of this appendix

This appendix addresses a common concern raised during budget reviews, audits, bond disclosures, and council deliberations:

“Population-based forecasts seem too simplistic or speculative.”

The purpose here is not to argue that population is the only factor affecting local government costs, but to demonstrate that population-driven forecasting—when anchored to development approvals and adjusted for service standards—is methodologically sound, observable, and conservative.


A.1 Population forecasting is not speculative in local government

A frequent misconception is that population forecasts rely on demographic projections or external estimates. In practice, this model relies primarily on the city’s own legally binding approvals.

Population growth enters the forecast only after it has passed through:

  • Annexation agreements
  • Zoning entitlements
  • Preliminary and final plats
  • Infrastructure construction
  • Utility connections
  • Certificates of occupancy

These are public, documented actions, not assumptions.

Key distinction for reviewers:
This model does not ask “How fast might the city grow?”
It asks “What growth has the city already approved, and when will it become occupied?”


A.2 Population is treated as a leading indicator, not a lagging one

Traditional population measures (census counts, ACS estimates) are lagging indicators. This model explicitly avoids relying on those for near-term forecasting.

Instead, it uses development milestones as leading indicators, each with increasing certainty and narrower timing windows.

For audit and disclosure purposes:

  • Early-stage entitlements affect only long-range capacity planning
  • Staffing and capital decisions are triggered only at later, high-certainty stages
  • Near-term operating impacts are tied to utility connections and COs

This layered approach prevents premature spending while avoiding reactive under-staffing.


A.3 Fixed minimums prevent over-projection in small or slow-growth cities

A common audit concern is that per-capita models overstate staffing needs.

This model explicitly separates:

  • Fixed baseline capacity (α)
  • Incremental population-driven capacity (β)

This structure:

  • Prevents unrealistic staffing increases in early growth stages
  • Accurately reflects real-world minimum staffing requirements
  • Explains why per-capita ratios vary by city size

Auditors should note that this approach is more conservative than straight-line per-capita extrapolation.


A.4 Service standards are explicit policy inputs, not hidden assumptions

Population does not automatically dictate staffing levels. Staffing reflects policy decisions.

This model requires the city to explicitly state:

  • Response time targets
  • Service frequency goals
  • Coverage expectations
  • Hours of operation

As a result:

  • Changes in staffing can be clearly attributed to either population growth or policy change
  • Council decisions are transparently reflected in forecasts
  • The model separates “growth pressure” from “service enhancements or reductions”

This clarity improves accountability rather than obscuring it.


A.5 Facilities and capital projections follow staffing, not speculation

Another concern raised by reviewers is that population forecasts may be used to justify premature capital expansion.

This model deliberately enforces a sequencing discipline:

  1. Population approvals observed
  2. Staffing thresholds reached
  3. Facility capacity constraints identified
  4. Capital expansion triggered

Facilities are not expanded because population might grow, but because staffing—already justified by approved growth—can no longer be accommodated.

This mirrors best practices in asset management and avoids front-loading debt.


A.6 Operating cost estimates use industry-standard unit costs

Electricity, maintenance, custodial, and lifecycle costs are estimated using:

  • Per-square-foot benchmarks
  • Historical city utility data where available
  • Conservative unit assumptions

These are not novel or experimental methods. They are the same unit-cost techniques commonly used in:

  • CIP planning
  • Facility condition assessments
  • Energy benchmarking
  • Budget impact statements

Auditors should view these estimates as planning magnitudes, not precise bills—and that distinction is explicitly stated in the model documentation.


A.7 The model is testable and falsifiable

A major strength of this approach is that it can be validated against actual outcomes.

As certificates of occupancy are issued:

  • Actual population arrival can be compared to forecasts
  • Staffing changes can be reconciled
  • Utility consumption can be measured

This allows:

  • Annual recalibration
  • Error tracking
  • Continuous improvement

Models that can be tested and corrected are inherently more defensible than opaque judgment-based forecasts.


A.8 Why this approach aligns with rating-agency expectations

Bond rating agencies consistently emphasize:

  • Predictability
  • Governance discipline
  • Forward planning
  • Avoidance of reactive financial decisions

This framework demonstrates:

  • Awareness of growth pressures well in advance
  • Phased responses rather than abrupt spending
  • Clear linkage between approvals, staffing, and capital
  • Conservative treatment of uncertainty

As such, population-driven forecasting anchored to development approvals should be viewed as a credit positive, not a risk.


A.9 Summary for reviewers

For audit, disclosure, and governance purposes, the following conclusions are reasonable:

  1. Population growth in cities is observable years in advance through public approvals.
  2. Using approved development as a population driver is evidence-based, not speculative.
  3. Fixed minimums and service-level inputs prevent mechanical over-projection.
  4. Staffing precedes facilities; facilities precede capital.
  5. Operating costs scale predictably with assets and space.
  6. The model is transparent, testable, and adjustable.

Therefore:
A population-driven forecasting model of this type represents a prudent, defensible, and professionally reasonable approach to long-range municipal planning.


Appendix B

Consequences of Failing to Anticipate Population Growth

A diagnostic review of reactive municipal planning

Purpose of this appendix

This appendix describes common failure patterns observed in cities that do not systematically link development approvals to population, staffing, and facility planning. These outcomes are not the result of negligence or bad intent; they typically arise from fragmented information, short planning horizons, or the absence of an integrated forecasting framework.

The patterns described below are widely recognized in municipal practice and are offered to illustrate the practical risks of reactive planning.


B.1 “Surprise growth” that was not actually a surprise

A frequent narrative in reactive cities is that growth “arrived suddenly.” In most cases, the growth was visible years earlier through zoning approvals, plats, or utility extensions but was not translated into staffing or capital plans.

Common indicators:

  • Approved subdivisions not reflected in operating forecasts
  • Development tracked only by planning staff, not finance or operations
  • Population discussed only after occupancy

Consequences:

  • Budget shocks
  • Emergency staffing requests
  • Loss of credibility with governing bodies

B.2 Knee-jerk staffing reactions

When growth impacts become unavoidable, reactive cities often respond through hurried staffing actions.

Typical symptoms:

  • Mid-year supplemental staffing requests
  • Heavy reliance on overtime
  • Accelerated hiring without workforce planning
  • Training pipelines overwhelmed

Consequences:

  • Elevated labor costs
  • Increased burnout and turnover
  • Declining service quality during growth periods
  • Inefficient long-term staffing structures

B.3 Under-sizing followed by over-correction

Without forward planning, cities often alternate between two extremes:

  1. Under-sizing due to conservative or delayed response
  2. Over-sizing in reaction to service breakdowns

Examples:

  • Facilities built too small “to be safe”
  • Rapid expansions shortly after completion
  • Swing from staffing shortages to excess capacity

Consequences:

  • Higher lifecycle costs
  • Poor space utilization
  • Perception of waste or mismanagement

B.4 Obsolete facilities at the moment of completion

Facilities planned without reference to future population often open already constrained.

Common causes:

  • Planning based on current headcount only
  • Ignoring entitled but unoccupied development
  • Failure to include expansion capability

Consequences:

  • Expensive retrofits
  • Disrupted operations during expansion
  • Shortened facility useful life

This is one of the most costly errors because capital investments are long-lived and difficult to correct.


B.5 Deferred capital followed by crisis-driven spending

Reactive cities often delay capital investment until systems fail visibly.

Typical patterns:

  • Fire stations added only after response times degrade
  • Police facilities expanded only after overcrowding
  • Utilities upgraded only after service complaints

Consequences:

  • Emergency procurement
  • Higher construction costs
  • Increased debt stress
  • Lost opportunity for phased financing

B.6 Misalignment between departments

When population intelligence is not shared across departments:

  • Planning knows what is coming
  • Finance budgets based on current year
  • Operations discover impacts last

Consequences:

  • Conflicting narratives to council
  • Fragmented decision-making
  • Reduced trust between departments

Population-driven forecasting provides a common factual baseline.


B.7 Overreliance on lagging indicators

Reactive cities often rely heavily on:

  • Census updates
  • Utility consumption after occupancy
  • Service call increases

These indicators confirm growth after it has already strained capacity.

Consequences:

  • Persistent lag between demand and response
  • Structural understaffing
  • Continual “catch-up” budgeting

B.8 Political whiplash and credibility erosion

Unanticipated growth pressures often force councils into repeated difficult votes:

  • Emergency funding requests
  • Mid-year budget amendments
  • Rapid debt authorizations

Over time, this leads to:

  • Voter skepticism
  • Council fatigue
  • Reduced tolerance for legitimate future investments

Planning failures become governance failures.


B.9 Inefficient use of taxpayer dollars

Ironically, reactive planning often costs more, not less.

Cost drivers include:

  • Overtime premiums
  • Compressed construction schedules
  • Retrofit and rework costs
  • Higher borrowing costs due to rushed timing

Proactive planning spreads costs over time and reduces risk premiums.


B.10 Organizational stress and morale impacts

Staff experience growth pressures first.

Observed impacts:

  • Chronic overtime
  • Inadequate workspace
  • Equipment shortages
  • Frustration with leadership responsiveness

Over time, this contributes to:

  • Higher turnover
  • Loss of institutional knowledge
  • Reduced service consistency

B.11 Why these failures persist

These patterns are not caused by incompetence. They persist because:

  • Growth information is siloed
  • Forecasting is viewed as speculative
  • Political incentives favor short-term restraint
  • Capital planning horizons are too short

Absent a formal framework, cities default to reaction.


B.12 Summary for governing bodies

Cities that do not integrate development approvals into population-driven forecasting commonly experience:

  1. Perceived “surprise” growth
  2. Emergency staffing responses
  3. Repeated under- and over-sizing
  4. Facilities that age prematurely
  5. Higher long-term costs
  6. Organizational strain
  7. Reduced public confidence

None of these outcomes are inevitable. They are symptoms of not using information the city already has.


B.13 Closing observation

The contrast between proactive and reactive cities is not one of optimism versus pessimism. It is a difference between:

  • Anticipation versus reaction
  • Sequencing versus scrambling
  • Planning versus explaining after the fact

Population-driven forecasting does not eliminate uncertainty. It replaces surprise with preparation.


Appendix C

Population Readiness & Forecasting Discipline Checklist

A self-assessment for proactive versus reactive cities

Purpose:
This checklist allows a city to evaluate whether it is systematically anticipating population growth—or discovering it after impacts occur. It is designed for use by city management teams, finance directors, auditors, and governing bodies.

How to use:
For each item, mark:

  • Yes / In place
  • ⚠️ Partially / Informal
  • No / Not done

Patterns matter more than individual answers.


Section 1 — Visibility of Future Population

C-1 Do we maintain a consolidated list of annexed, zoned, and entitled land with estimated buildout population?

C-2 Are preliminary and final plats tracked in a format usable by finance and operations (not just planning)?

C-3 Do we estimate population by development phase, not just at full buildout?

C-4 Is there a documented method for converting lots or units into population (household size assumptions reviewed periodically)?

C-5 Do we distinguish between long-range potential growth and near-term probable growth?

Red flag:
Population is discussed primarily in narrative terms (“fast growth,” “slowing growth”) rather than quantified and staged.


Section 2 — Timing and Lead Indicators

C-6 Do we identify which development milestone triggers planning action (e.g., preliminary plat vs final plat)?

C-7 Are infrastructure completion schedules incorporated into population timing assumptions?

C-8 Are water meter installations or equivalent utility connections tracked and forecasted?

C-9 Do we use certificates of occupancy to validate and recalibrate population forecasts annually?

C-10 Is population forecasting treated as a rolling forecast, not a once-per-year estimate?

Red flag:
Population is updated only when census or ACS data is released.


Section 3 — Staffing Linkage

C-11 Does each major department have an identified population or workload driver?

C-12 Are fixed minimum staffing levels explicitly separated from growth-driven staffing?

C-13 Are staffing increases tied to forecasted population arrival, not service breakdowns?

C-14 Do hiring plans account for lead times (recruitment, academies, training)?

C-15 Can we explain recent staffing increases as either:

  • population growth, or
  • explicit policy/service-level changes?

Red flag:
Staffing requests frequently cite “we are behind” without reference to forecasted growth.


Section 4 — Facilities and Capital Planning

C-16 Are facility size requirements derived from staffing projections, not current headcount?

C-17 Do capital plans include expansion thresholds (e.g., headcount or service load triggers)?

C-18 Are new facilities designed with future expansion capability?

C-19 Are entitled-but-unoccupied developments considered when evaluating future facility adequacy?

C-20 Do we avoid building facilities that are at or near capacity on opening day?

Red flag:
Facilities require major expansion within a few years of completion.


Section 5 — Operating Cost Awareness

C-21 Are operating costs (utilities, maintenance, custodial) modeled as a function of facility size and assets?

C-22 Are utility cost impacts of expansion estimated before facilities are approved?

C-23 Do we understand how population growth affects indirect departments (HR, IT, finance)?

C-24 Are lifecycle replacement costs considered when adding capacity?

Red flag:
Operating cost increases appear as “unavoidable surprises” after facilities open.


Section 6 — Cross-Department Integration

C-25 Do planning, finance, and operations use the same population assumptions?

C-26 Is growth discussed in joint meetings, not only within planning?

C-27 Does finance receive regular updates on development pipeline status?

C-28 Are growth assumptions documented and shared, not implicit or informal?

Red flag:
Different departments give different growth narratives to council.


Section 7 — Governance and Transparency

C-29 Can we clearly explain to council why staffing or capital is needed before service failure occurs?

C-30 Are population-driven assumptions documented in budget books or CIP narratives?

C-31 Do we distinguish between:

  • growth-driven needs, and
  • discretionary service enhancements?

C-32 Can auditors or rating agencies trace growth-related decisions back to documented approvals?

Red flag:
Growth explanations rely on urgency rather than evidence.


Section 8 — Validation and Learning

C-33 Do we compare forecasted population arrival to actual COs annually?

C-34 Are forecasting errors analyzed and corrected rather than ignored?

C-35 Do we adjust household size, absorption rates, or timing assumptions over time?

Red flag:
Forecasts remain unchanged year after year despite clear deviations.


Scoring Interpretation (Optional)

  • Mostly ✅ → Proactive, anticipatory city
  • Mix of ✅ and ⚠️ → Partially planned, risk of reactive behavior
  • Many ❌ → Reactive city; growth will feel like a surprise

A city does not need perfect scores. The presence of structure, documentation, and sequencing is what matters.


Closing Note for Leadership

If a city can answer most of these questions affirmatively, it is not guessing about growth—it is managing it. If many answers are negative, the city is likely reacting to outcomes it had the power to anticipate.

Population growth does not cause planning problems.
Ignoring known growth signals does.


Appendix D

Population-Driven Planning Maturity Model

A framework for assessing and improving municipal forecasting discipline

Purpose of this appendix

This maturity model describes how cities evolve in their ability to anticipate population growth and translate it into staffing, facility, and financial planning. It recognizes that most cities are not “good” or “bad” planners; they are simply at different stages of organizational maturity.

Each level builds logically on the prior one. Advancement does not require perfection—only structure, integration, and discipline.


Level 1 — Reactive City

“We didn’t see this coming.”

Characteristics

  • Population discussed only after impacts are felt
  • Reliance on census or anecdotal indicators
  • Growth described qualitatively (“exploding,” “slowing”)
  • Staffing added only after service failure
  • Capital projects triggered by visible overcrowding
  • Frequent mid-year budget amendments

Typical behaviors

  • Emergency staffing requests
  • Heavy overtime usage
  • Facilities opened already constrained
  • Surprise operating cost increases

Organizational mindset

Growth is treated as external and unpredictable.

Risks

  • Highest long-term cost
  • Lowest credibility with councils and rating agencies
  • Chronic organizational stress

Level 2 — Aware but Unintegrated City

“Planning knows growth is coming, but others don’t act on it.”

Characteristics

  • Development pipeline tracked by planning
  • Finance and operations not fully engaged
  • Growth acknowledged but not quantified in budgets
  • Capital planning still reactive
  • Limited documentation of assumptions

Typical behaviors

  • Late staffing responses despite known development
  • Facilities planned using current headcount
  • Disconnect between planning reports and budget narratives

Organizational mindset

Growth is known, but not operationalized.

Risks

  • Continued surprises
  • Internal frustration
  • Mixed messages to council

Level 3 — Structured Forecasting City

“We model growth, but execution lags.”

Characteristics

  • Population forecasts tied to development approvals
  • Preliminary staffing models exist
  • Fixed minimums recognized
  • Capital needs identified in advance
  • Forecasts updated annually

Typical behaviors

  • Better budget explanations
  • Improved CIP alignment
  • Still some late responses due to execution gaps

Organizational mindset

Growth is forecastable, but timing discipline is still developing.

Strengths

  • Credible analysis
  • Reduced emergencies
  • Clearer governance conversations

Level 4 — Integrated Planning City

“Approvals, staffing, and capital move together.”

Characteristics

  • Development pipeline drives population timing
  • Staffing plans phased to population arrival
  • Facility sizing based on projected headcount
  • Operating costs modeled from assets
  • Cross-department coordination is routine

Typical behaviors

  • Hiring planned ahead of demand
  • Facilities open with expansion capacity
  • Capital timed to avoid crisis spending
  • Clear audit trail from approvals to costs

Organizational mindset

Growth is managed, not reacted to.

Benefits

  • Stable service delivery during growth
  • Higher workforce morale
  • Strong credibility with governing bodies

Level 5 — Adaptive, Data-Driven City

“We learn, recalibrate, and optimize continuously.”

Characteristics

  • Rolling population forecasts
  • Development milestones tracked in near-real time
  • Annual validation against COs and utility data
  • Forecast errors analyzed and corrected
  • Scenario modeling for alternative growth paths

Typical behaviors

  • Minimal surprises
  • High confidence in long-range plans
  • Early identification of inflection points
  • Proactive communication with councils and investors

Organizational mindset

Growth is a controllable system, not a threat.

Benefits

  • Lowest lifecycle cost
  • Highest service reliability
  • Institutional resilience

Summary Table

LevelDescriptionCore Risk
1ReactiveCrisis-driven decisions
2Aware, unintegratedLate responses
3StructuredExecution lag
4IntegratedFew surprises
5AdaptiveMinimal risk

Key Insight

Most cities are not failing—they are stuck between Levels 2 and 3. The largest gains come not from sophisticated analytics, but from integration and timing discipline.

Progression does not require:

  • Perfect forecasts
  • Advanced software
  • Large consulting engagements

It requires:

  • Using approvals the city already grants
  • Sharing population assumptions across departments
  • Sequencing decisions intentionally

Closing Observation

Cities do not choose whether they grow. They choose whether growth feels like a surprise or a scheduled event.

This maturity model makes that choice visible.