Virginia's Data Centers Are Coming for the Water: 2 Million Gallons a Day in Culpeper

What the document says

A Reclaimed Water System Agreement obtained through a Virginia FOIA request reveals the terms of a deal between the Town of Culpeper, Virginia and SAC III Acquisition Co., LLC -- a Delaware shell entity operating under the name STACK Infrastructure -- for a data center campus called the Culpeper Technology Campus.

The agreement grants STACK the primary right to consume up to 2 million gallons per day of the town's reclaimed wastewater for industrial data center cooling. The pump system is designed for a firm capacity of 4 million gallons per day -- twice the initial allocation -- suggesting the infrastructure is being built to scale well beyond what has been disclosed.

STACK is paying for the entire reclaimed water system: a new pump station at the town's wastewater treatment plant, 4,600 linear feet of 16-inch pipe, an elevated 2-million-gallon storage tank at the data center site, UV disinfection upgrades, and chemical treatment systems. The town will own the infrastructure once it is built. STACK gets first rights to the water.

Groundwater while they wait

Until the reclaimed water system is built and connected, the agreement allows STACK to draw up to 500,000 gallons per day of groundwater as temporary bridging water for up to one year after the first building receives its occupancy permit. That one-year limit can be extended if delays are not STACK's fault.

The town is connecting two reserve wells -- X4B and X2A -- with a combined safe yield of 500,000 gallons per day from the town's potable water system to feed the data center during this bridging period. In a rural Virginia county that depends on groundwater for drinking water, half a million gallons per day is not a rounding error.

The agreement also notes that roughly 30 percent of the reclaimed water STACK uses will be returned to the wastewater treatment plant for re-treatment. That means the facility's net water consumption is approximately 1.4 million gallons per day -- still enough to supply a town of several thousand people.

What Culpeper County already said no to

The Culpeper Technology Campus is being developed within the Town of Culpeper. But Culpeper County -- the surrounding jurisdiction -- has already rejected data center proposals twice.

The county denied Amazon's rezoning request for a 250 MW data center campus, with residents arguing that data centers were incompatible with the county's agricultural character. Separately, county planners recommended denial of a 460 MW data center campus at Brandy Station, citing incompatibility with the area's Civil War battlefield heritage and rural character.

The pattern is striking: the county said no. The town said yes. The same water table, the same community, two different answers. STACK's agreement with the town locks in water rights that the county's residents have been fighting to protect.

Virginia's water problem is bigger than Culpeper

Culpeper is not an isolated case. Across Virginia, data centers are consuming water at industrial scale while operating under a regulatory framework that was designed for a different era.

In Loudoun County, 4,700 diesel generators are permitted with a combined capacity of 12 gigawatts. The 2026 General Assembly passed 15 data center bills, including mandates for Tier IV emissions standards on new generators. But water consumption has received far less legislative attention than air quality or energy demand.

The state's data center sales tax exemption costs an estimated 1.6 billion dollars per year. A special session was scheduled for April 23 to resolve a budget standoff over whether to keep or kill the break. None of the 15 bills that passed in 2026 specifically addressed water consumption by data centers.

Meanwhile, STACK's agreement in Culpeper shows the industry is not waiting. The infrastructure is being designed, the wells are being connected, and the water rights are being locked in -- one town at a time.

Read the document yourself

We are publishing the full Reclaimed Water System Agreement because the public has a right to see the terms under which their water is being committed. The document was obtained through a Virginia Freedom of Information Act request.

The agreement includes Exhibit 1, which details the wastewater treatment plant upgrades, the pump station specifications, the pipeline route, the elevated storage tank design, and the well water backup system. It names the engineering firms (Peterson Companies for design, WW & Associates for permitting and inspection) and the legal entity behind STACK (SAC III Acquisition Co., LLC, registered in Delaware, with a legal address at 1700 Broadway, Suite 1750, Denver, Colorado).

Download the full agreement: poweredbywho.com/documents/culpeper-stack-reclaimed-water-agreement.pdf

If you have access to the Water Services Agreement referenced in the document, the DEQ permit application, or any communications between the Town of Culpeper and STACK about water allocation, we want to hear from you. Submit a tip at poweredbywho.com/tips.