Data Center Related Surety Bonds

Potential Sites for Data Centers
Why Former Mine Sites Are Being Considered

Across the United States, thousands of former mining sites stand idle -- neither used nor repurposed. Often these sites are in areas that have experienced economic decline and present environmental challenges such as costly reclamation and remediation. At the same time, the rapid expansion of artificial intelligence, cloud computing, and digital infrastructure is driving unprecedented demand for new data center locations. These parallel trends have prompted developers, policymakers, and engineers to explore whether former mine properties could be transformed into viable technology campuses.

Modern data centers require substantial parcels of land, reliable power access, and effective heating and cooling solutions. Former mining properties are large, comprising several acres, allowing for initial construction and future expansion. They may already have industrial zoning classifications, existing roads, electrical infrastructure including transmission lines and substations, and other infrastructure to reduce permitting delays and construction costs. In addition, such sites are frequently located in regions seeking economic revitalization and replacement of lost tax revenues, making them attractive candidates for redevelopment initiatives.

Another key advantage is cost. Properties with prior industrial use or environmental limitations can often be acquired at lower prices than undeveloped land near metropolitan areas. For companies planning major infrastructure investments, this cost difference can significantly enhance project feasibility. Further, the location of these mines may serve to mitigate the concerns local residents have with the development of data centers in their area.

In a few places in the United States, such as an Iron Mountain data center in Boyers, PA, a data center has been located inside an abandoned limestone mine. Northeastern Pennsylvania boasts an abundance of abandoned anthracite coal mines in counties including Luzerne, Lackawanna, Schuylkill, and Northumberland. Yet despite the nearly 10,000 abandoned mines in the state, no data center has been constructed inside or on the surface of any abandoned underground coal mine in Pennsylvania. In western Pennsylvania, a data center is proposed to be built at the former Robena Mine site in Greene County, and span 1,400 acres along the Monongahela River. And in Washington County, the proposed “Zediker Station” data center is to be located on a 1,500-acre former coal mining site.

Zoning and Land Development Consideration

From a legal standpoint, one of the most significant hurdles is that many municipal zoning codes were written before data centers became common infrastructure. In some jurisdictions, then, the term “data center” does not appear in zoning definitions. Further, using abandoned coal mining sites and the water at these sites presents novel issues that have not previously been addressed by municipalities in Pennsylvania. Such issues can affect project timelines because variances or special exception approvals often require planning commission review, public notice, and hearings before local governing bodies. In addition, large facilities typically qualify as major land developments, triggering additional land development requirements.

Engineering and Environmental Considerations

A key issue relating to the use of abandoned mines and the use of mine water concerns compliance with applicable laws and regulations. Specifically, the reclamation of mines in Pennsylvania is governed by the federal Surface Mining Control and Reclamation Act (SMCRA). This Act provides that states eligible for reclamation under the act must also prepare and submit a State Reclamation Plan. Pennsylvania's Abandoned Mine Reclamation Plan, originally prepared in 1983, was updated in 1992 and 1997 to incorporate changes resulting from congressional amendments to SMCRA.

Further, the federal Clean Water Act and Pennsylvania’s Clean Streams Law, both of which address water quality, may impact data center development at former mine sites.

Interaction with Pennsylvania’s Department of Environmental Protection will be necessary to identify permits and approvals that may be required.

Former mine properties present engineering challenges that must be evaluated carefully. Notably, ground stability concerns and incomplete site data can complicate construction planning.

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