Wenning Environmental

Underwater Data Centers Need Above-Water EIAs

Richard J Wenning, Wenning Environmental LLC, Portland, Maine, US

Published on JD Supra, 06 May 2026

ABSTRACT:

Driven by AI-fueled data demands and local NIMBY concerns over land and utility usage, underwater data centers are emerging as an innovative, space-saving alternative that utilizes passive aquatic cooling to lower energy consumption. However, as the projected global market for data centers skyrockets from USD 976 million in 2020 to USD 14 billion by 2035, environmental impact assessments (EIAs) must address the ecological uncertainties. While early pilot projects and commercial setups—such as Microsoft’s Project Natick, China’s Highlander clusters, and Subsea Cloud’s Jules Verne pod—have reported minimal ecological disturbances, some experts speculate that future growth of large-scale underwater data centers risks localized thermal pollution, disrupting underwater acoustics and electromagnetic fields, endangering marine life, and threatening sensitive benthic habitats. Ultimately, because these facilities still rely heavily on land-based electricity networks, independent life-cycle assessments and strict decommissioning frameworks are likely needed to align the industry with regional, national, and international marine protection goals.