Shelby County
Neutral Data Center Policies
Shelby County allows data-processing uses as offices, but data centers are not specifically named, so approval may be uncertain. Ordinary site-plan and utility requirements may add time or cost; no special data-center ban is described.
current law · Unincorporated areasEstablishes binding zoning, subdivision, and development requirements for Memphis and unincorporated Shelby County, covering land use, building envelopes, infrastructure, parking, landscaping, stormwater, natural resources, and public improvements; no development may proceed without prior authorization under the Unified Development Code.Shelby County Zoning Regulations
What this means
Data centers are not specifically named, so approval may involve some uncertainty, though the code lists data processing as an office use. Ordinary site-plan and utility requirements may add some time or cost, but there is no special ban or major data-center restriction.
Restrictions & requirementsHide restrictions & requirements23
A data center is not expressly listed as a principal use. It is prohibited unless the Zoning Administrator determines it is similar to a permitted use; otherwise, a zoning text amendment is required before it may be allowed. Any applicable standards or special-use review for the similar use also apply.
If a proposed data center includes multiple principal uses in different use categories, each use must satisfy its applicable regulations, and the entire development is reviewed under the most restrictive approval process applicable to any proposed use.
New construction and qualifying changes, expansions, or parking-area expansions for a data center generally require administrative site plan review. No building permit may be issued, and construction or alteration may not begin, until the applicable site plan is approved.
Data centers classified as office uses generally must provide one off-street parking space per 300 square feet of floor area; a call-center classification requires one space per 150 square feet. The CBD, SCBID, and MU districts have no minimum off-street parking requirement, and an alternative parking plan may be requested with supporting parking data.
When applicable development thresholds are met, a data center must comply with district and development-type requirements for streetscapes, access management, parking and loading, landscaping and screening, outdoor storage, lighting, and signs.
New outdoor lighting at a data center abutting or immediately across a public right-of-way from a single-family residential zoning district, when applicable development thresholds are met, requires compliance with the outdoor-lighting code, including a lighting plan, fixture cut sheets, lumen limits, and backlight, uplight, and glare limits.
Major loading areas must generally be screened from residential properties and public rights-of-way, located to the side or rear of the building unless fully enclosed and not visible, and set back at least 25 feet from an abutting single-family residential district.
Major utility infrastructure must generally be screened by a Class III landscape buffer or an approved equivalent alternative. Required access ways to major utilities are exempt from the screening requirement.
A data center in a mixed-use or industrial district without public water must generally be on a site of at least four acres, subject to Shelby County Health Department approval. A site with public water but without public sewer or an approved individual treatment facility must generally be at least two acres and is also subject to Health Department approval.
New building construction and certain expansions in the Medical Overlay, University District Overlay, and SCBID special districts require site plan review. The expansion trigger is removal of more than 25% of existing walls facing a public street or more than 50% of all exterior walls, subject to limited exceptions for certain single-family residential projects.
Site plan review may require dedication and improvement of public streets, sidewalks, and other public infrastructure, and approval may be conditioned to address traffic, parking, public facilities, natural features, and effects on surrounding properties.
Before required public improvements are constructed, approved plans, profiles, specifications, and applicable right-of-way or street or utility-cut permits are required. Required improvements must be covered by a standard improvement contract.
Required public improvements generally must be secured by a performance bond, cash deposit, certificate of deposit, or irrevocable letter of credit. A full bond must cover 100% of estimated improvement costs, and off-site public improvements must be fully bonded.
Developers must pay the costs of connecting to required public utilities, including water, sanitary sewer, and stormwater improvements. Where public water is within a reasonable distance, the applicant may be required to fund the connection, and sewer extensions may be required to serve upstream development.
All development, including data-center development, is subject to the Memphis and Shelby County Storm Water Management Manual and its stormwater design and compliance requirements.
Tree removal generally requires a notice of intent filed 10 to 45 working days before removal, a tree survey, and, in specified circumstances, a tree-removal permit. Exceeding the tree-removal matrix can require replacement with four live trees of at least 2.5-inch caliper for each removed tree or payment to the tree bank.
Trees designated for preservation must be protected by fencing or barriers at least three feet high extending ten feet beyond the trunk. Construction materials, debris, equipment, and vehicles are prohibited within the protection zone.
Development on natural steep-slope areas of at least 5,000 square feet and 25% grade is limited: no more than 15% of the site's steep-slope area may be graded, and development must minimize disturbance to the natural landform.
Stream buffers must be maintained on both sides of qualifying streams, with a minimum width of 30 feet unless a greater width is required. Buildings must be set back at least 10 feet from the buffer, and most activities within the buffer are prohibited except limited utility and infrastructure work.
A proposed subdivision of at least five acres or 50 lots located partly or entirely in an A-zone special flood hazard area, when required flood-elevation or floodway data is unavailable, must submit detailed hydrologic and hydraulic plans prepared by a registered professional engineer.
New electric utility services generally must be placed underground where functionally feasible, and electrical substations must be at least 100 feet from the nearest property line of a parcel in a single-family residential zoning district.
In the Medical Overlay and University District Overlay, trash, recycling, loading, and mechanical equipment must meet enhanced location and screening requirements, including opaque service-area enclosures at least eight feet high and, in specified cases, a 50-foot separation from residentially zoned property.
Within the Medical Overlay, surface parking lots are prohibited unless accessory to a permitted principal use or approved by special exception. Required parking may be reduced by up to 25% only under the overlay's stated parking provisions.
Benefits & exceptionsHide benefits & exceptions17
Data processing is expressly included among office uses, allowing a data center to be evaluated within the Code’s Office use category rather than as an unlisted use: offices including ... data processing.
The Employment (EMP) District accommodates office, research and development, light manufacturing, warehousing, wholesale, processing, and commercial uses, providing zoning options for different data-center configurations: office, light manufacturing, research and development, warehousing.
The Warehouse and Distribution (WD) District allows office/warehouse, warehouse/distribution, and wholesale uses and recognizes high-traffic, 24-hour operations: broad range of office/warehouse.
Office, light-industrial, warehouse/distribution, and heavy-industrial uses may include accessory offices, parking, storage, electric-vehicle charging, and accessory solar or building-mounted wind systems: Accessory solar energy system.
Utility facilities are recognized as permitted use categories, including electrical substations, electric or gas transmission facilities, water and wastewater pump stations, and major utility facilities: Minor utilities, including ... electrical substation.
Campus Master Plan districts accommodate office, research and development, light manufacturing, and processing uses, with clustering opportunities intended to improve efficiency: allowing for clustering opportunities.
Within CMP-1 and CMP-2 Internal Campus areas, outdoor-lighting and outdoor-storage standards do not apply internally. Lighting at the district edge must still comply with Code limits, and infrastructure, parking, landscaping, access, and natural-resource requirements remain applicable: the standards of Chapter 4.7 ... shall not apply.
Planned Development approval may provide relief from district and other Code requirements and allow flexible land-development and site-design techniques. It is available for any-size tract in Memphis and for tracts of at least three acres in unincorporated Shelby County, subject to findings concerning compatibility, infrastructure, landscaping, and the public interest: providing relief from district requirements.
No minimum off-street parking is required in the CBD, SCBID, or MU Districts: No minimum off-street parking spaces are required.
Ground-mounted photovoltaic systems smaller than 20 acres within the fenced area may be accessory uses in all zoning districts when primarily serving on-site consumption and remaining incidental and subordinate to a permitted principal use; building-mounted photovoltaic systems are accessory uses in all districts: permitted as an accessory use in all zoning districts.
Electric transmission and distribution feeder lines and communications trunk and feeder lines may be placed above ground within easements or public rights-of-way; other new electric services must be underground only where functionally feasible: Electric transmission and distribution feeder lines and communications trunk and feeder lines may be placed above ground.
Administrative site plan review is available for qualifying new construction, expansions, and parking construction or expansion in SCBID special-purpose districts. The Medical Overlay and University District Overlay also provide administrative review for most development other than exclusively residential single-family projects: Applications shall be reviewed administratively.
Existing nonconforming uses in SCBID districts and certain overlay districts are governed by Article 10, providing continued regulatory treatment if an existing facility later does not conform to changed district standards: Existing nonconforming uses are governed by Article 10.
Parking reductions of up to 25 percent are allowed in the Medical Overlay District based on public transportation availability, subject to applicable geometric requirements and possible special-exception modifications: Parking reductions of up to 25 percent are allowed in the Medical Overlay District.
A building permit issued before the effective date of the Code or a later amendment remains effective if development began within six months and the permit remains valid under the building code: shall remain in effect provided that development has started within six months.
Complete zoning and subdivision applications pending when the Code became effective are processed under the law in effect when filed: complete and pending at the effective date.
Previously approved planned developments and planned commercial districts generally remain governed by their existing governing-body conditions. Uses permitted under a former zoning classification remain permitted rather than becoming nonconforming: those uses permitted under the former zoning district classification shall be permitted.
Sources
Specific to Shelby County only.
pending · Unincorporated areasWould set water- and electricity-conservation requirements for new and existing data centers in unincorporated Shelby County; a separate proposed moratorium of up to 12 months was also under consideration.Shelby County Data Center Regulatory Ordinance — Amber Huett-Garcia Proposal (2026)
What this means
The proposed moratorium could pause county data-center development for up to 12 months, a major temporary barrier (moratorium not to exceed 12 months). A separate proposal would add water- and electricity-conservation rules for new and existing centers, but the sources do not describe those requirements in detail.
Timing
- Ends
- no more than 12 months
The proposed county moratorium is temporary, but its vote was delayed. The sources do not specify when the 12-month period would begin.
People behind it
- Amber Huett-Garcia
Sponsored the county ordinance proposing water and electricity conservation rules and requirements for existing data centers.
- Henri Brooks
Sponsored the proposed temporary county moratorium on data centers, which would last up to 12 months.
- Erika Sugarmon
Co-sponsored the proposed temporary county moratorium on data centers, which would last up to 12 months.
Restrictions & requirementsHide restrictions & requirements3
Memphis passed a 135-day moratorium on data centers, temporarily restricting development during that period. 135-day data center moratorium
Shelby County is considering a temporary data center moratorium of up to 12 months; the Commission delayed its vote while the proposal is further developed. temporary moratorium that does not exceed 12 months
A proposed Shelby County ordinance would regulate new and existing data centers in unincorporated areas, including water- and electricity-conservation requirements and requirements for existing facilities. regulations on new and existing data centers
Sources
Specific to Shelby County only.
pending · Unincorporated areasWould require new data centers in unincorporated Shelby County to meet water- and electricity-conservation rules, if adopted.Shelby County Data Center Moratorium — Henri Brooks and Erika Sugarmon Proposal (2026)
What this means
The proposed county ordinance would add meaningful operating requirements, including water and electricity conservation rules and measures addressing noise and water use (proposed rules). It is not an outright ban, but the added requirements could raise costs for new and existing facilities; the details were still being revised (regulations on new and existing data centers).
People behind it
- Amber Huett-Garcia
Sponsored the proposed county data-center regulatory ordinance.
- Henri E. Brooks
Sponsored and introduced the proposed 12-month county data-center moratorium.
- Erika Sugarmon
Co-sponsored Brooks’ proposed county moratorium.
Show 1 more peopleShow fewer people
- JB Smiley
Sponsored the Memphis City Council’s proposed extended data-center moratorium.
Restrictions & requirementsHide restrictions & requirements5
Memphis’s ordinance imposes a 135-day moratorium on data-center applications. 135-day moratorium on data center applications
Memphis’s ordinance requires closed-loop water systems and water conservation. installing closed-loop water systems
Memphis’s ordinance requires phasing out carbon-based energy. phasing out carbon-based energy
Shelby County’s proposed ordinance would require water and electricity conservation; it was still being revised and had not yet received a final commission vote. include water and electricity conservation requirements
A proposed Shelby County measure would impose a 12-month moratorium on data centers in the county; the commission delayed further action while amendments were worked on. 12-month moratorium
Benefits & exceptionsHide benefits & exceptions1
The Memphis ordinance creates a digital infrastructure development district, although the source does not specify what support or benefits the district provides. The ordinance includes creating a digital infrastructure development district.
Sources
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