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Article

Clicking and Swiping Away: Hidden Implications of Australian Data Center Water Security and Management

by
Angela T. Ragusa
1,* and
Andrea Crampton
2
1
School of Social Work and Arts, Charles Sturt University, Albury, NSW 2640, Australia
2
School of Dentistry and Medical Sciences, Charles Sturt University, Albury, NSW 2640, Australia
*
Author to whom correspondence should be addressed.
Water 2026, 18(2), 136; https://doi.org/10.3390/w18020136
Submission received: 27 November 2025 / Revised: 1 January 2026 / Accepted: 3 January 2026 / Published: 6 January 2026
(This article belongs to the Section Water Resources Management, Policy and Governance)
Versions Notes

Abstract

The Australian public and broader society have little awareness of the seminal relationship between water supply and data usage/storage. Most data centers (DCs) consume large volumes of water to operate servers that supply digital society’s instantaneous 24/7 information communication systems. DC water consumption is a global issue that lacks transparency, sustainable management, and effective governance. This article analyzes current Australian legislation, policies, and industry sustainability plans to examine whether and in what ways the absence of clear water governance requirements for DC may contribute to state and national water insecurity. It shows how academic and applied discourses conceptualize, research, and respond to DC sustainability as an energy issue. This conceptualization masks the relevance of DC water usage/security. The results show that Australian legislation, policy, planning, and management lack sufficient transparency and state governance regarding the industry’s water use and accountability. Global and national DC certifications are discussed, and policy solutions are recommended to mitigate future DC pressure on water supply and related consequences. Our conclusions advocate the necessity of improving public awareness, industry accountability, and government management strategies (policy and legislation) for sustainable water practices in Australia, as artificial intelligence increases DC quantity and size, exacerbating supply and consumption in local environments that legislate against nuclear energy alternatives.

1. Introduction

People have come to rely on tapping, swiping, and clicking digital devices (mobile phones, computers, watches, etc.) daily to search vast quantities of online data, game, bank, exchange bitcoin, navigate automobiles, etc. The Internet supports a globalized economy [1] and social interconnectivity among family, friends, and communities. A plugged-in leisure society and workplaces reliant on global corporations (e.g., Google, Apple, Amazon, Netflix), however, consume vast amounts of natural resources, such as water. Water consumption rates from online activities are currently hidden from view—sociologically out of practical consciousness due to the structural organization of society [2]. Data centers (DCs) are key elements of the infrastructure that enable digital society’s information retrieval. The social connection between Internet provision, DCs, and total environmental impact, however, is ambiguous and insufficiently transparent.
To date, disproportionate focus exists on DC energy usage at the expense of water consumption transparency. A critical literature review suggests that this is largely because environmental sustainability goals prioritize reducing carbon emissions. In 2025, DCs accounted for 0.5% of fuel combustion-generated CO2 emissions, a figure set to double to 1% by 2030 [3]. Cloud-based data storage and artificial intelligence (AI) supply placed unprecedented demand on energy resources, leading to urgent calls for more sustainable practices from industry leaders, policymakers, and government officials [3,4,5]. In terms of global electricity consumption, this translates to 1.5% consumed in 2024, which is estimated to rise to 3% by 2030 [3]. With the increasing incorporation of energy-hungry AI into everyday public lifestyles, particularly Internet searches, the proportion of global energy usage will likely surpass these predictions. In areas with high DC density, such as Ireland and Denmark, energy use is predicted to exceed 16% of their national energy consumption [6].
Ever-rising energy consumption needs for today’s digital lifestyle have spurred global efforts to offset environmental impacts. These are reflected in a popular discourse about DC sustainability, where focus on energy consumption discusses goals and expectations around “power use efficiency” (PUE) with little regard or reporting of the vast amount of water often used to cool DCs [3]. This invisibility is not new; earlier attempts to calculate DC water footprints also note that inconsistent reporting and limited disclosure make accurate assessment difficult [7]. This article commences by investigating DCs and water consumption governance in Australia. Such exploration is necessary since cooling mechanisms can be responsible for 7–30% of a center’s electricity consumption (depending on efficiency and cooling type, with liquid-based systems being more energy-efficient than refrigerated air) [4]. However, in considering DC water consumption, the core water-use metric for DC—water-use efficiency (WUE)—is not a measure of the actual water used but rather a relative water-use measure based on the amount of energy consumed [3]. Although engineering research has long explored technical strategies to reduce cooling-related water demand [8], such work has not translated into transparent or standardized water-use reporting within industry sustainability practice. Hence, although using liquid instead of air-conditioning to cool data servers conserves 95% of cost and reduces emissions by nearly 45%, industries predict that global AI demand will double DC energy consumption in two years [7]. This would equal Japan’s 125 million population usage, as “the hundreds of millions of daily queries asked of ChatGPT, as just one example, cost around 1 GWh of energy each day…the equivalent of the daily energy consumption of about 33,000 households” ([9], p. 2). If we factor water consumption into this increased demand, by 2027, it is estimated that DCs will use 1.7 trillion gallons of water globally, approximating six times Denmark’s annual water usage [10]. Hence, the discursive framing of DC as an “energy issue” renders the substantial impact of global water consumption invisible.
Sociologically, the classic works of Simmel provide a theoretical framework for conceptualizing how “ideas embedded in everyday practices of life and discourse” [2,11] reflect systemic organization. Society’s conceptualization of information and communication technologies’ (ICTs) environmental footprint—as an “energy management” issue—has environmental, socioeconomic, and political ramifications for water governance and water availability. DC’s current trajectory is a socioenvironmental problem. Currently, over 10% of the global population and more than 60% of irrigated agricultural lands are experiencing high-to-critical levels of water stress that negatively affect food availability [12]. The latest estimates predict that at least 50% of the global population will experience water stress by 2050 [3]. All those in the Middle East and North Africa will have water insecurity [13]. Unlike energy, water is not a renewable resource.
A clear divide exists in the industry around “transparency” about the type of water used for DC cooling. Facebook and Digital Reality provide clear breakdowns, but Google, Amazon, and Apple do not provide detailed reporting despite corporate promotion that they are innovative users of alternative water sources, including recycled water or seawater [4]. Further, reported WUE refers to direct water use (i.e., at the site), while (often substantial) indirect water use associated with electricity generation is excluded in water efficiency measures [4]. This exclusion, namely, corporate failure in measuring all aspects of DC water usage, is relevant and timely. Several multinational corporations (Google, Amazon, Microsoft, and Meta) recently invested in nuclear energy plants for reliable renewable energy needs to meet PUE and net-zero goals in operating locations [14]. Nuclear energy, however, uses similar volumes of water as coal energy-based production, underscoring the need for site-based WUE (the current metric) and energy-source-based WUE metrics (i.e., WUE-source) to evaluate DC sustainability and water efficiency [15]. Recent modelling of the increased data usage by individuals, for predicted energy and water needed to permit such usage, forecasts that by 2030, the average European will require more water to support their data use than they need for drinking [16].
A recent international review of DC sustainability standards identified that most of the 86 standards/frameworks/regulations [17] focused on energy and carbon. Further, energy and carbon-related standards were the most widely adopted and had the biggest impact [17]. Although prior research shows WUE featured in non-European countries (notably Singapore, India, and Malaysia) [17], global WUE attention may be changing as the “Climate Neutral Data Center Pact”, a group of DC operators working together to meet European “Green Deal” objectives, set a WUE target of 0.4 L/kWh or less by 2040 [3]. Currently, although the global WUE average is 0.5 L, many American DCs operate between 1 and 1.5 L, whilst Asian-Pacific DCs approximate 1.65 L [3]. Nevertheless, research shows that DCs with some water efficiency tend to adopt the LEED (Leadership in Energy and Environmental Design) system [17].
Australia’s stable political climate and proximity to large Asia-Pacific markets (having high cloud and data demands) contribute to its continued DC construction, with clear concentration in two main capitals, Sydney and Melbourne [18,19]. By 2029, Australian DC construction is forecasted to reach 4.46 billion, a 6.1% increase from 2023 [20]. As it is cheaper to build DCs in Australia than Malaysia, Singapore, or Indonesia, this growth is not purely to serve domestic markets; Australian DC construction is an economic initiative aiming to capitalize on the faster-growing Asian market. The Australian Government notes Western Australia and the Northern Territory as emerging hubs due to their proximity and direct cabling to Asian markets, which is furthered by their access to abundant renewable energy [19]. The renewable energy requirement for government-certified DCs, ahead of widespread adoption and availability, is a potential barrier to their construction in regional Australia [20]. Without reliable access to renewable energy that would allow large multinational corporations operating in Australia (including Amazon, Equinix, NextDC, and Google) to meet renewable energy sustainability goals, higher water use may result from American and European nuclear power station investments [14]. In locations such as Australia’s Northern Territory, where GreenSquareDC purchased 3100 ha of land to generate renewable energy to service its DC, water-friendly sources are necessary because of water scarcity and government prohibition of nuclear energy power plant construction [19]. Growing scrutiny of AI’s increased environmental impact, nuclear energy, and DCs in Australian news media has prompted calls for greater transparency in actual water use related to local environments. The industry, in response, has criticized the media for using averages and for making inferences that have negative implications, rather than reporting actual water use [21]. Most Australian DCs are less than ten years old, with approximately half being under five years old. Thus, increased DC transparency in actual water use would be advantageous for Australian centers even in the absence of legislation requiring disclosure.
This article commences a timely task of academic and practical importance: investigating certified DC water consumption, transparency, management, and governance in Australia. In a historical milieu of high digital literacy and usage, Australia’s water footprint from DC consumption rivals water-affluent societies, whilst farmers are beset by cyclical droughts that decimate economies and communities [22,23]. Little legislation and enforceable policy exist to support national water security by regulating DC water consumption or supply. The Australian public and global society have little awareness of the seminal relationship between water supply, data usage, and data storage. Public discourse exhibits preoccupation with energy sustainability, which, we argue, comes at the cost of water security prioritization. Thus, this article fills an academic and applied knowledge gap. By documenting the lack of social awareness, industry accountability, and government management of water sustainability for digital undertakings requiring DCs, this article contributes to the call by an Australian Government review of DCs to examine ways policy can be adapted to encourage better water efficiency [24]. This is achieved through policy and legislation analysis. Making transparent the infrastructure requirements necessary for us to “click and swipe away” on our ICT devices is essential for improving individual and societal approaches to water, a vital non-renewable resource.

2. Materials and Methods

This study set out to identify how many Australian DCs are government-certified and what legislation and policy govern their water usage and management. Three research questions are posed: (1) What policy guides national and state-level Australian DC water consumption and management? (2) Does Australian legislation and/or certification include enforceable DC water practice governance? (3) What water security planning exists for sustainable DC growth and consumption? Collectively, these questions enable comparative analyses of how the state—sociologically, a major social institution wielding sizable power in globalized society [25]—facilitates or thwarts water security for a multinational industry with substantial influence and projected growth locally and globally.
The social science research method of qualitative content analysis (QCA) was chosen to answer these questions. QCA is an established method that is well-suited for comparative policy analysis [26]. The optimization of reliability, trustworthiness, and validity was supported by following critical QCA protocols [27]. These include obtaining a complete sample from reliable, credible publicly available government sites, reporting verbatim quotations to avoid interpretive bias, and presenting results using institutional policy to support international comprehension in a systemic context [28,29]. QCA permitted identifying and analyzing Australian water governance related to DCs because (a) of the applied implications of DC’s increased water needs and (b) the research literature’s predominant focus on energy. As a secondary data analysis of publicly available documents, human ethics research clearance was not required. Generative AI was not used for either the research conducted or the writing of this article.
To locate what laws, policies, guidelines, strategies, and strategic plans currently govern the national and state water management of certified Australian DCs and investigate DC water accountability, research sampling focused on documents relating to water and climate governance, planning, and management. The title of each document analyzed is included to support data transparency and accessibility. Sampling was undertaken in three stages.
Stage 1 consisted of identifying the environmental certification status of DC entities across all states and territories. The sampling criteria used to select DC entities were their obtainment of Australian Government certification by June 2025. This criterion was chosen because government certification is the most reliable and objective measure available, requiring demonstrated maintenance of operational quality levels for water security and environmental sustainability. Fifty DC entities were found. These are managed by 13 companies. Stage 1 focused explicitly on identifying and analyzing certified DC industry sustainability policy and guidelines relative to their geophysical location in specific Australian states and territories. The Australian Government’s hosting certification system is designed to align the procurement of services with relevant government policies, including environmental sustainability. Narrowing the sampling framework to certified physical DC structures suited the research objective to align policy analysis with the physical structures to which they most directly apply. Further, this supports the broader purpose of documenting strategic change. Application of this sampling criterion produced a sample of five states/territories operating a certified DC (Canberra, New South Wales, Queensland, Victoria, Western Australia), with the remaining two (Northern Territory and South Australia) excluded. Policy analysis, executing QCA of DC inclusion/exclusion, was undertaken for these five locations to identify the extent of enforceable water governance.
Stage 2 focused on locating Australian water and climate policy, plans, and legislation. All Australian DCs require planning approval for operation. Since planning restrictions, including environmental planning, vary by state, sampling necessitated a state-level framework to execute a national analysis. The state-level sample was generated by searching government websites and databases for policies, plans, and strategies using the keywords “data centre”, “cloud”, “ICT”, and “digital”. This was refined to exclude documents only referring to issues of data sovereignty or cybersecurity. Further document reading required additional filtering. A general discussion of data hosting, data use, or data management, rather than physical DC, was also excluded from the final sample. This produced a total of 17 documents authored by varied branches of the Australian Government. Policy analysis commenced by reading each strategy, plan, report, agreement, and program. Pilot codes for manifest content were created. Manifest coding identifies explicit terms and phrases related to the research topic, which supports data validity and the reliability of findings by minimizing the potential for subjectivity bias, as expressed by quantitative researchers [30].
Finally, in Stage 3, to permit a comprehensive comparative analysis of land planning and environmental assessment frameworks across Australian states and territories, the primary “umbrella” legislation governing land planning in each jurisdiction was identified. This approach ensured that the foundational statutory framework (relevant to development assessment and environmental considerations) was captured by the state and territory. The selected umbrella acts identified were as follows: Environmental Planning and Assessment Act 1979 (New South Wales), Planning and Environment Act 1987 (Victoria), Planning Act 2016 (Queensland), Planning and Development Act 2005 (Western Australia), Planning, Development and Infrastructure Act 2016 (South Australia), Land Use Planning and Approvals Act 1993 (Tasmania), and Planning and Development Act 2007 (Australian Capital Territory). Manifest and latent coding were conducted for all policies and legislation to determine DC inclusion in national governance related to water security, water scarcity, water potability, water use, and water supply.

3. Results

3.1. Australian DC Certification and Environmental Credentialing

Of the 50 Australian DC entities found, 21 are certified strategic facilities and thus can be termed a “whole DC” (or “campus”) that meets the requirements of the National Australian Built Environment Rating (NABER) system, which grants Australian Government hosting certification. The other 29 entities are certified strategic “enclaves”. Enclaves are a designated section of a DC, or campus, adapted to meet hosting certification requirements yet have a discernible perimeter separating them from other parts of the DC. Table 1 presents the voluntary environmental certification status of DC facilities and enclaves by location.
The results show that five DC entities obtained a NABERS rating. Only one (Equinix SY7) achieved the hosting certification specifications that came into effect on 1 July 2025. Government policy provides a one-year extension for entities to complete the steps required for compliance. NABERS, the key instrument employed by the Australian Government to assess and enforce core sustainability measures for DC [33], has the capacity to incorporate “water efficiency” into its rating system. This is not available yet for DC [34], despite some reports claiming otherwise [35]. Whilst water efficiency ratings exist for shopping centers, public hospitals, apartment buildings, schools, residential aged-care, and hotels [34], the 5-star rating for DCs with government hosting certification only relates to PUE, with no water efficiency requirements. This lacks alignment with the goals of the European industry group, Climate Neutral Data Center Pact [36]. For any DC, not only those seeking Australian Government hosting certification, higher ratings offer eligibility to earn a 20% tax rebate following the clean building investment structure [37]. Existing regulations also provide scope for NABERS alternatives, such as the green-star rating managed by the Green Building Council of Australia, which currently lacks DC-specific certification, with water considerations limited to the carbon emissions of water consumed [38].
The requirement that Australian Government DCs utilize accreditable “green power” from renewable energy sources shows potential to reduce stress on water sources, given the water intensity of increased power production. For example, NSW has the most certified DCs. Despite the state’s large hydroelectric systems, over 30% of NSW’s power still comes from water-intensive coal-fired power plants [39]. All DCs with a NABERS rating, except NextDC Perth, rely on more than 78% non-renewable energy, whilst the outlier utilizes 26% renewable energy and has onsite solar generators [40].
Additionally, companies with global DC operations, such as Equinix, Fujitsu, NextDC, and Digital Realty, have sought and achieved internationally recognized certifications. International certification systems used by Australian DCs include LEEDS (Leadership in Energy and Environmental Design), which is managed by the U.S. Green Building Council [41], and ISO (International Organization for Standardization). ISO14001 is the international standard required for environmental management systems that support DCs addressing water efficiency.
Of the 50 certified entities investigated, 20 have ISO 14001 certification. Certification requires entities to demonstrate ongoing water conservation steps as relevant to industry standards. A further 11 entities have the newer version of the certification, ISO 14001:2015. The ISO 14001:2015 certification adds more layers of proactive planning and water management in a local context (as opposed to an industry standard) and requires greater data transparency and reporting of water usage to relevant stakeholders [32]. Ten of the ISO 14001:2015 certified centers are managed by one international provider, NextDC. The remainder includes one of the newest centers, DBI, run by Cloud Carriers. DBI represents a new generation of DCs and poses the least water management concern because it is designed to utilize on-site water harvesting.
In an Australian business context, international certification is voluntary. Sustainability requirements for Australia’s DC water security are currently unknown, whilst the most recent international DC reporting reveals that less than half of DC owners measure factors needed to assess their sustainability, including those with regulatory requirements [42]. Although DC certification provides for proactive management of natural resource use, in order for decision-making to be aligned to local contexts (e.g., Australian drought conditions), greater data transparency and the reporting of water usage to stakeholders are required [32]. International standards do not establish water efficiency levels, nor do they constitute formalized processes that are enforceable nationally.

3.2. National and State Water and Climate Policy Analysis

Table 2 depicts Australian policy documents and legislation related to “water” and “climate” governance.
Manifest coding revealed that only one policy document, Australian Government Net Zero (2023) [43], includes the keyword “data centre”. As federal or national policy guiding Australian Government operations, this strategy is administered by the Minister for Finance. It explicitly aims to reduce public service operations to zero emissions by 2030 to mitigate climate change impacts. DCs are discussed in two key arenas. First, the NABERS rating “based on the facility’s actual operational data, not design” was established in 2023 to indicate “operational energy efficiency and environmental impact of data centres, with a rating from one to 6 stars” (p. 17). In 2025, DC governance related to NABERS changed: “From 1 July 2025, new data centre facilities that are sourced outside of the Panel arrangement, whether owned or leased by the Commonwealth, are also required to achieve and maintain a rating of 5 stars or equivalent environmental rating” (p. 17). The policy clearly stipulates that existing DCs are included and that accreditation is mandatory:
data centres run by an entity must obtain a NABERS Energy for Data Centres infrastructure rating. If the facility cannot be improved to meet the 5 star rating, the entity should optimise the data centre’s energy efficiency in its setup and operation.
(p. 17)
Second, the policy documents the establishment of the DC panel, which oversees NABERS:
“with strengthened measures for data centre providers to identify, manage and reduce their greenhouse gas emissions. Future panels will incorporate NetZero considerations to enable entities to identify, report and reduce their emissions from ICT usage”, where ICT “includes computers, servers, monitors and mobile phones”
(p. 17)
The remaining sixteen documents appearing in Table 2 do not explicitly mention DC, revealing no manifest content. Seven codes encapsulate manifest policy and legislative content for water governance: water supply, water use/usage, drought, water security, water scarcity, water potability, and drinking water. These codes are collapsed into the 5 categories appearing in Table 2.
Latent QCA of these sixteen documents, organized by state, found that NSW’s Climate Change Policy Framework [44] excludes DCs, discusses “security” only in relation to energy policy, and mentions “water” in one sentence under “policy directions”:
“The government will provide long-term and coordinated efforts to increase the resilience of our primary industries and rural communities as climate change impacts water availability and water quality”.
(p. 8)
Likewise, the NSW Climate Change (Net Zero Future) Act 2023 (p. 8) [45] makes one mention of “water” as one of ten “guiding principles”: “the need to ensure essential utilities and infrastructure are provided, including energy, water, telecommunications and transport”. The Net Zero Plan Stage 1 2020–2030 [46] discusses water as being able to be made from hydrogen in its focus on renewable energy technologies. Improved water efficiency is described as resulting from an NSW government-supported initiative, citing NABERS as allowing commercial offices to monitor water usage. Although a case study of a cotton farmer who switched from diesel to solar–diesel irrigation is highlighted in agricultural and commercial industry discussions, DCs remain absent.
Victoria’s Climate Change Strategy [47] (p. 14) gives a cursory mention of “water”. This appears in the statement, “Climate action will also help protect our precious flora and fauna and improve the health and wellbeing of our community by restoring landscapes and reducing pollution of our water, air and soil”. Aside from “efficient hot water” system targets, Victoria’s strategy for water aims to include resilient farms and forests for improved water quality, reducing water pollution by diverting landfill waste, and meeting water cycle targets. The concept of “security” only relates to the energy power supply. Victoria’s Water Cycle Climate Change Adaptation Plan 2022–2026 [48], however, is a 78-page document where “water” appears 1255 times. The plan covers water cycles, risks, climate change, adaptation, supply, infrastructure, assets, community, resilience, efficiency, legislation, monitoring, evaluation, and exemplars. The key aims include revitalizing outdated infrastructure to support supply and security and create a circular economy, yet it excludes DCs.
Queensland’s Climate Adaptation Strategy 2017–2030 [49] focuses on coastal risks, supply, quality, treatment, sewerage, and storms in conjunction with “water”, offering a moderate discussion of water-related climate concerns. DCs do not appear. Contrastingly, in Canberra, ICON Water’s Climate Change Adaption Plan [50] relates specifically to water and presents a comprehensive 50-page strategic plan detailing risk assessment, action plans, and mitigation strategies for events, including bushfires, floods, storms, water security, and management related to drought, infrastructure, catchments, supply, availability, recycled water, and a host of external and social factors. This also excludes DCs. Similarly, Western Australia extensively includes water-related topics in its Climate Policy Plan [51]. To provide water security in a drying climate, its strategies are desalination, efficient social housing, recycling, and groundwater replenishment.
Comparing state water strategies, NSW’s Greater Sydney Water Strategy [52] expansively covers drinking water, catchments, mining, environmental flows, water sharing, storage, treatment, supply, quality, management, risk, cultural values, recreation, monitoring, evaluation, infrastructure, governance, groundwater, runoff, water cycles, floodplains, drought, economics, desalination, usage, and population growth. DCs fail to be mentioned, however, in the discussion of Sydney’s water planning up to 2060. Queensland’s Water Strategy [53] is divided into four major foci: 1. healthy waterways, rivers, aquifers, and sustainable water management; 2. First Nations partnerships, access, and ownership; 3. water for regional economic prosperity; 4. safe and secure water supply. None includes DCs. Canberra’s Water Strategy 2014-44 [54] also excludes DCs, focusing on similar areas as NSW, such as adaptation, climate change, recreation, supply, efficient usage, catchments, sustainability, waterways, monitoring and evaluation, health risks, flooding, stormwater, planning, cultural values plus national water reform, water trading, and regional foci such as the Murray Darling Basin. Western Australia’s Water Action Plan [55] focuses on reduced water availability from multiple sources, outlining the need for “waterwise” communities and related practice change. Sixteen 2030 targets are identified, with none including DC. Lastly, Victoria’s Greater Melbourne Urban Water Strategy [56] contains over 200 pages of global and local challenges in identifying how Australia’s second largest metropolis will address water security, risks, climate change, availability, management, health, environment, and cultural water needs, yet it makes not one reference to technology or DCs.

3.3. National and State Legislation and Planning Analysis for Water and DCs

All federal legislation regulating environmental aspects of water security and management for Australian DC is governed by The National Greenhouse and Energy Reporting Act 2007, No. 175, 2007 [57]. This Act is supported by The Rules: Energy for Data Centres [58], published April 2024. The Act is administered by the state government, specifically New South Wales. Other existing pieces of legislation related to DC governance issues, such as cybersecurity, are covered, but not water.
The Digital Transformation Agency manages the hosting certification framework (HCF), which provides relevant accreditation to entities seeking government business [59]. Environmental concerns and goals set by the NGER Act require certified entities to meet conditions related to lowering PUE and emissions. Specifically, these include having a target PUE of less than 1.4 (the current industry standard is 1.5 [60]), a 5-star NABERS rating or equivalent, using accredited green power from renewable resources, and, if not already net zero, a plan to achieve it [33]. DCs without government hosting certification are only required to meet the regulations of the NGER Act [57] as a commercial entity and only if their energy consumption reaches a given threshold [57]. While the National Construction Code sets energy provision for other commercial buildings, relevant standards and means of assessing DC are lacking [61].
The Australian Government positions DC and cloud services as critical infrastructure needed to meet Digital Economy Strategy 2030 [62] goals, revealing DC’s crucial role in the Australian economy [63]. A function of the Government’s role, however, also includes managing greenhouse gas targets, specifically a 43% reduction goal by 2030 and net zero by 2050 [63]. Two major pieces of legislation, the Security of Critical Infrastructure (SOCI) Act, 2018 [64] and the National Greenhouse and Energy Reporting (NGER) Act, 2007 [57] affect the DC governance of the numerous nationwide frameworks, policies, and strategies. DCs that seek to provide services to, or on behalf of, the Australian Government are subject to the most stringent levels of regulation under these federal acts.
Five state and federal acts were found that actively govern water in 2025. Manifest QCA found that none included the term “data centre”, with variation by state for the other five keywords (Table 3). Latent QCA of Australian legislation identified “matters of national environmental significance” in the Planning & Development Act, 2023 [65], which are subsumed under the Environment Protection and Biodiversity Conservation Act 1999 [66]. These include heritage properties/places, wetlands, threatened species/ecological communities, internationally agreed protection of migratory species, nuclear activating, and water resources related to coal seam gas and large coal mining development. Legislation stipulates water flow, supply, storage, and protection regarding catchments, reserves, areas, and development/planning for domestic and commercial activity, without mention of DC. By state, NSW’s Environmental Planning and Assessment Act 1979; 2025 [45] provides for Sydney’s drinking water catchment planning, policy, and development governance by the Minister, with use approvals governed by the Water Management Act 2000 [67] and other acts, such as the Fisheries Management Act 1994 [68], Protection of the Environment Operations Act 1997 [69], Roads Act 1993 [70], and Water Management Act 2000 [67], for carrying out management activities related to public water. The Act also sets out restrictions for water suppliers/providers, with potability extensively governed by drinking water legislation without the use of the keyword “potable” or its derivatives. NSW and Canberra legislation have over 4000 pages of law. Victoria has a Water Minister responsible for the Act’s administration, alongside Environment and Planning Ministers. Councils, water corporations, and multiple sectors of state government are defined and specified, with flood but not drought management noted. Similarly to NSW, waste/sewerage, sustainability, contamination, and development planning constitute the Act’s key foci. Contrastingly, no mention of drinking water or potability is observable. Further, a close reading of Victoria’s Planning and Environment Act 1987; 2025 [71] for content shows that “security” refers to fiscal, not water, security. This further evidences the robustness of combining latent and manifest analysis.
Queensland’s Planning Act 2016; 2025 [72] utilizes a definition most closely approximating the UN’s Sustainability Goals. Specifically, it advocates, “conserving, enhancing or restoring…water for present and future generations” (p. 22, S4). Further, it promotes the “sustainable use of renewable and non-renewable natural resources, including biological, energy, extractive, land and water resources” (p. 25, S6) in relation to economic development. Queensland’s Act refers to its Coastal Act in discussing tidal water management, with specific mention of canals and high-/low-water development requirements, compared with the NSW and Victorian Acts. Like the other states, Queensland’s Act governs water management related to planning, infrastructure, utility approval, compliance, and/or development, excluding DC specification and likewise showing the expansive inclusion of cultural heritage compliance. No mention of drinking water appears in Queensland’s Act.
Lastly, Western Australia’s Planning and Development Act 2005; 2025 [73] contains the least manifest reference to water, with governance specifically of utilities, Crown-land subdivisions, easements, and specific water bodies, such as catchments and reserves. Like other states, it includes water conservation/preservation, alongside cultural heritage and infrastructure development/maintenance clauses. Western Australia’s Act is about a third in size and scope, which reflects the state’s smaller population size.
No official documentation was identified in Canberra or Victoria that explicitly mentions DC. One document was found for Western Australia that discusses DCs and government policy. The Department of Jobs, Tourism, Science, and Innovation produced a 2022 marketing prospectus, WA: The southern hemisphere’s global hub for data centre operations [74], promoting the state’s leadership in cyber-security and digital technology to attract DC. It advocates that “Western Australia is an ideal location for data centres with an abundance of affordable, low-emissions energy sources and expanding renewable energy capacity” (p. 14). Further added is the statement, “We also have the capacity to support data centres of different scales, ranging from edge data centres to mid-scale commercial and hyper scale operations” (p. 15), whilst promoting “water availability”. To counter its known dryness, the government document asserts its water sustainability (p. 15):
Western Australia was the first State in Australia to develop large scale demand management and water supply initiatives. This has enabled significant diversification in water supply sources to be achieved over the past 20 years, removing reliance on streamflow to dams. The present mix of water sources in Perth include desalination, groundwater and surface dams.
[74]
Western Australia’s government also offers hands-on assistance with “Case management of specific large-scale data centre proposals” (p. 16). Western Australia offers an example of how state-level DC legislation could incorporate water efficiency alongside new, greener DCs. The Western Australian Government displays awareness of DC’s water-intensive propensity by promoting its desalination plants (some fueled by renewable energy) as reliable water source alternatives on an as-needed basis to the limited public supply [75]. Western Australia is not a water-abundant location; the government concurrently encourages individual and commercial consumers to be “water wise” and advocates water conservation and resource preservation [75]. The promotion of the state’s suitability as a DC hub by the Australian Government’s key international trade advocacy body, AUSTrade, focuses on low-cost electricity and ample space for DCs to host their own renewable energy sources [19].
Although no DC planning document was identified for Queensland, the Digital and Innovation section of its State Infrastructure Strategy [76] (pp. 47–53) presents DCs as a case example of the Queensland Capacity Network (QCN) Fibre, which is, “the state government’s telecommunications carrier, jointly owned by Powerlink and Energy Queensland”. It states that “High capacity backhaul is provided to strategically important data centres in regional areas”, without any mention of water. Finally, and in contrast, six NSW documents relate to DCs and planning policy (Government Resource Efficiency policy [77], Cloud Policy [78], Cloud Strategy [79], State Significant Development Guidelines, Part 8 [80], Environmental Planning and Assessment Regulations 2021 [45], and the Planning Secretary Environmental Assessment Requirements [81]). Only two of these mention water, and both do so in a planning context. The Government Resource Efficiency policy [77] contains general water sustainability goals that are not specifically related to DCs. The Planning Secretary’s Environmental Assessment Requirements [81] link water use to the government’s net-zero emissions and related considerations for water consumption through water-sensitive urban design. Although requirements exist for surface and ground water impact assessments, including water quality, no volumetric limits or considerations specific to the ongoing drawing of water by DCs appear.

4. Discussion

The myriad of legislative and strategic instruments investigated in this policy analysis, as well as the variation in environmental accreditation measures exhibited by the DC industry, provide evidence-based academic research that highlights the common perception in recent Australian news media that DC water use is inadequately disclosed. The lack of clear and consistent Australian legislative and policy tools poses socioenvironmental problems for water resource management, measurement, and accountability. In a political context where states actively induce DC operators to expand, despite water managers’ warning that infrastructure may be inadequate if increased demand pressures water supply [82], the forecasted rise in data storage and use is of national and global concern.
Our results first highlight the need for national and international DC sustainability rating systems to incorporate actual water use, promote water conservation as a priority, and require more accurate measurements that are transparent and inclusive of water usage. Such measures are needed to improve national and local water security. Second, we highlight that only one Australian DC currently meets the 2025 NABERS certification at the time of publication. Third, we note that the international certification systems that the DC industry voluntarily pursues to improve their sustainability image are based on European and American geographies, which have vastly different water profiles. This warrants action. Third, this analysis demarcates five interconnected limitations that impede the accurate assessment of DC water consumption in the Australian context. Three of these constraints—namely, inconsistent definitions of WUE [4], the routine exclusion of indirect water use associated with electricity generation [3], and the separation of direct site-based use from broader system-level consumption [3]—are well established in the international literature and reflect long-standing challenges in assessing DC sustainability [3,4,15]. The remaining two limitations—absence of transparent reporting of actual volumetric water use and limited disclosure of cooling-system configurations—emerged directly from our analysis of Australian DC data transparency. Analyses of Australia’s governance landscape reveal that DC certification, policy, and legislation [33,57,58] exhibit these limitations. Collectively, these intertwined barriers constitute a structural measurement gap that currently precludes methodologically robust modelling, comparison, or monitoring of water use. Rather than representing a technical inconvenience, these barriers underscore the systemic nature of the governance deficit identified throughout this article. Importantly, they also delineate the minimum transparency and reporting requirements needed for a credible water-accountability framework. In short, effective DC governance in Australia requires the incorporation of enforceable, locally contextualized water-use metrics alongside existing energy-focused instruments.
Although LEEDS certification includes water efficiency elements, the current version supporting “new” DC certification relates to building design and construction (BD + C). Points are awarded for efficient cooling towers, outdoor water use, indoor water use, and the use of water for chillers and humidifiers based on water reduction from “baseline” measures. This system does not measure actual water consumption. So, while DC design may indicate water efficiency, certification fails to provide evidence of water efficiency. LEEDS certification for operations and maintenance (O + M) is for “existing” buildings and does require performance data to demonstrate reduction from a historical baseline or industry benchmark. While not measuring actual water usage, it can support water management and facilitate awareness. Like Australia’s NABERS certification, LEEDS 5 mandates using renewable energy [83].
Renewable energy is the pervasive focus of multinational technology companies with large DC demands, such as Google, Microsoft, and Meta, who recently made commitments to nuclear energy production [14]. Water, however, is a non-renewable, finite natural resource. Our results show that water and its security are de-emphasized in DC operations and governance focus. Whilst some companies are making a commitment to be water positive [84], this does not necessarily prevail at individual DC sites. “Blue washing” occurs, with operators appearing in alignment with government net-zero emission goals, whilst citizens in areas of water stress—where new DCs are being built—are left with greater water and food security pressure [84]. Our research has shown that this remains invisible and largely lacks enforceable governance.
Without legislative enforcement and/or ISO 14001:2015 certification (or similar), the industry remains free to select what works best for its multiple bottom lines. Global DC industry monitoring reports note that indicators of DC water efficiency require local contextualization and that construction dynamics should be considered rather than creating a simplified metric [21]. Dietrick [21] notes that old servers have higher water use and stresses the relevance of climatic conditions, competition for available water sources, and watershed dynamics when considering water consumption. DCs built post-2020 have highly efficient cooling systems that either negate the continued need to replenish water or require substantially less water than older systems, although the optimal water use is best achieved in regions with lower temperatures [21]. Overall, balancing energy and water efficiency is compounded by DC designs formulated in water-rich areas that encourage energy-efficiency prioritization. As technological innovations make waterless cooling a reality and as Microsoft’s commitment to converting all DCs to waterless [21,85] manifests and leads industry practice, the principal focus on energy may suit water-rich DC locations better than drier locations like Australia. Conversely, waterless DCs may be a better approach than Google’s water-stewardship promises, which aim to be water positive by returning 120% of water to the environment but are, unfortunately, applied across the enterprise rather than where DC water is extracted [86]. If waterless DCs demand nuclear energy, however, and the DC locations are in locations such as Australia, where legislation prohibits new nuclear power plants, this fails to offer a viable solution for sustainable DC water consumption or water security.
By focusing on DC governance, policy, planning, and legislation, our research reveals the lack of clarity and the need to systemically address and include water—as an urgent environmental consideration—in DC growth in Australia, particularly where nuclear energy is prohibited. DCs with government hosting certification display the clearest set of standards and expectations set by the federal government. Nevertheless, the government hosting of DC certification currently relies on self-rating and reporting. Given the noted lack of transparency, this system is also unlikely to assist local water managers in working with DC planners and operators. There may be certified entities with relevant ISO certification that have not chosen to publicly provide this information. It is important to note that our research, however, is reliant on the public availability of documents. Hence, future research may wish to seek out primary data to supplement these secondary sources.
An additional limitation of the current research is its timing. The NABERS requirement for a minimum 5-star rating came into effect during our investigation. As noted in the Introduction, this certification only relates to energy use and not water use. At the time of writing (November, 2025), four entities had actively renewed their NABERS rating since the new requirements came into effect, and at least one let its rating lapse; moreover, only one of the fifty entities met the new minimum standards. Thus, future research ought to check for updated data. Regardless of the quantity of DC certifications, NABERS, as a governing system, does have the capacity to engage with water-use metrics. Further, these could be locally tailored. Unfortunately, water metrics are currently not developed nor mandated for Australian DC. Thus, a key finding is that Australian legislation and guidelines are falling behind globally in DC water management and accountable/enforceable water conservation. Malaysia and Singapore have WUE requirements. India, Indonesia, and San Jose in America have water use conservation requirements. The European Union and the state of Utah in America are finalizing WUE and water conservation requirements [17]. Without a water accountability system that holistically enables the full and transparent reporting of actual water use, including that drawn from the system and used in power generation, it is unlikely that Australian water managers, local communities, or the public can truly appreciate the potential risks DC pose to water security in their area. Sociologically, it is the state that ultimately wields greater power over discourse and law enforcement regardless of public perception, which is influenced by media and popular culture.
As commercial entities, new DC approval in Australia hinges on planning legislation in localities. If classified as a “strategic entity”, they may be exempt from local laws in favor of state or federal instruments. While DCs are not directly discussed in planning documents as commercial entities, they are subject to relevant restrictions. Our analysis noted that Australian planning instruments give scant regard to potable water or water supply security. Thus, while strategic policy/plans are an important compliance step governing new buildings and exhibit environmental protection goals, their current foci inadequately promote the due consideration of location-based water management for potentially water-intensive users, as reflected by existing DC designs. Federal legislation, in contrast, provides scope to consider acceptable levels for water-intensive industries, particularly mining, yet currently, it is silent about DCs. Therefore, we are left with a situation where there are legislative instruments requiring environmental impact assessments (EIA), but the assessments inadequately address the unique water usage of water-cooled DCs.
Each state’s water policies/plans acknowledge water security concerns. Such concern is also evidenced federally. Concern, however, does not surpass general notions advocating “water conservation”. Legislative and regulatory instruments are available that would enable the government to directly address DC water conservation. Specifically, the 2025 NABERS for DC Government Hosting certification could include sustainable water use measures. Additionally, existing international certification systems (e.g., ISO 14001; 2015; LEED V5) could be utilized as requirements for all DCs rather than only those with government hosting certification. Australia does not need to create a new certification system; existing tools—particularly ISO 14001:2015, with its local context considerations and reporting transparency—are arguably already fit for the purpose. Existing certifications simply need to be incorporated into appropriate governance instruments and enforced. Such changes would proactively enforce governance that legislates water usage, so local and multinational DC commercial interests do not take precedence over national water security, including water for local residents and other industries, such as agriculture, necessary for food security.
In addition to strengthening the requirements and reach of NABERS, there is precedent for strengthening the environmental assessment and protection processes to better address the water-intensive nature of DC operations. In Australia, several water-intensive or high-impact industries already operate under sector-specific assessment and licensing frameworks that extend beyond generic project-level EIA. For example, mining is governed by dedicated instruments because its continuous and cumulative water impacts cannot be adequately managed through standard EIA alone [87,88]. Likewise, thermal power stations are subject to EPA licensing and water-pollution discharge assessments that set technology-specific conditions on cooling-water abstraction, amongst other aspects not covered by general planning instruments [89]. These precedents indicate that proposing DC-specific water disclosure or efficiency requirements within existing Australian legislative instruments is not exceptional; it aligns DCs with how Australia already governs other sectors for which their cumulative, cluster-level, and technology-dependent water footprints exceed the scope of generic EIA.

5. Conclusions

The Australian Government, like many others, has a target to reach net-zero emissions by 2050. Thus, it promotes adopting measures favoring renewable energy to reduce CO2 production. Australian DC discourse and management focus on PUE, particularly the industry’s proportion of renewable energy use [33]. The DC industry also focuses on energy sustainability to support continuous data consumption growth. This creates a tenuous context in Australia, the world’s driest inhabited continent, where water insecurity is an ecological, economic, and social problem [90]. DC operations require a sizable water supply, and in Australia, they rely on private industry motivation for water conservation. This poses a sizable risk to national water security (a public good) in a water-vulnerable location. Our analysis of DC governance and industry policy, plans, and strategies related to water and climate change and legislation at the state and federal levels evidences limited, if any, inclusion of water awareness in content and/or governance. This legislative and applied environment inhibits water management and security, poses water supply risks for other users, and reveals discord with international trends, specifically international DC certification systems that incorporate limited and general, but existing, water metrics.
The projected water consumption of a digital society increasingly reliant on AI, in locations such as Melbourne, where many of the nation’s DC are housed, shows the high cost of Australia’s exclusion and/or de-prioritization of water whilst over-focusing on energy sustainability. Melbourne, for example, uses ~50 L of water per second to operate 45 DCs; this is estimated to increase to 3000 L per second, equivalent to the water used by 100,000 homes [63]. Such changes in water use lack transparency, accountability, and issue awareness, whilst federal and state focus remains entrenched on PUE as government and industry aim for net zero. The federal government increasingly relies on large data hosting capabilities and does not own its own DCs. It does, however, have a robust set of criteria (a hosting certification framework) that government service providers must meet to obtain government business. This framework ensures the highest levels of security, data sovereignty, and alignment with environmental principles and targets [59]. Contrastingly, DC owners are responsible for managing and self-reporting sustainability metrics against standards rather than actual usage. Our article reveals the perils of this system, advocating that DCs require an independent and objective monitoring of all natural resources, particularly water, used and needed for operation, and we advocate for alignment with internationally recognized and locally informed sustainability criteria to more equitably secure water for current and future generations.

Author Contributions

Conceptualization, A.T.R. and A.C.; methodology, A.T.R. and A.C.; validation, A.T.R. and A.C.; formal analysis, A.T.R. and A.C.; investigation, A.T.R. and A.C.; resources, A.T.R. and A.C.; data curation, A.T.R. and A.C.; writing—original draft, A.T.R. and A.C.; writing—review and editing, A.T.R. and A.C. All authors have read and agreed to the published version of the manuscript.

Funding

This research received no external funding.

Data Availability Statement

All data used for this article are publicly available. This article contains citations for all documents used in our analysis. No new, primary data was generated.

Conflicts of Interest

The authors declare no conflicts of interest.

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Table 1. Environmental certification status of DC facilities (Fs) and enclaves (Es) by location.
Table 1. Environmental certification status of DC facilities (Fs) and enclaves (Es) by location.
CompanyCenter NameNABER RatingVoluntary
Environmental Credentials
New South Wales
AirTrunkSYD1-2 (F)NRNS
Canberra DCEC1-4 (F)NRNS
DCI DCSYD01 (E)NRNS
Digital RealtySYD10 (E)4 RISO 14001 [31]
Digital RealtySYD11 (E)4.5 RISO 14001
Digital RealtySYD14 (E)NRNS
Equinix AustraliaSY3 (E)NRISO 14001; LEED Gold
Equinix AustraliaSY4-5 (E)NRISO 14001; LEED Silver
Equinix AustraliaSY6 (E)NR PISO14001
Equinix AustraliaSY 7 (E)5ISO14001
Fujitsu AustraliaWestern Sydney (E)3.5 RISO14001
Fujitsu AustraliaHomebush (E)4 RISO14001
NextDC #Sydney 1NRISO14001:2015 [32]
NextDCSydney 2NRISO14001:2015
TelstraSt Leonard’sNRNS
Cloud CarrierDB1NRISO14001:2015
Canberra (Australian Capital Territory)
Australian DCADC Mitchell (F)NRNS
Canberra DCH1-H5 & F1-F2NRNS
Equinix AustraliaCA1NRISO14001
Macquarie TelecomIC1-5 (E)NRISO14001
NextDCCanberra 1 (E)NRISO 14001:2015
Victoria
AirTrunkMel 1 (F)NRNS
Digital RealtyMEL 1 (E)NRISO14001
Equinix AustraliaME2 (E)NRISO 14001: LEED—Silver
Equinix AustraliaME4 (E)NRNS
NextDCMelbourne 1-3 (E)NRISO 14001:2015
Queensland
iSEEK #LDR2 (F)NRNS
NextDCBrisbane 1-2 (E)NRISO 14001:2015
PolarisPolaris (E)NRISO14001
Western Australia
EquinixPE2-3NRISO14001; LEED certified (PE3 stage 1 only)
NextDCPerth 1NR PISO 14001; 2015
NextDCPerth 2NRISO 14001; 2015
Note: NR = Not rated as of 22 September 2025; NS = not-specified/information unavailable; # = recently purchased by HMC capital and former NEXTDC Sydney center now known as DGT SYD1; R = certification renewed after June 2025; P = previously certified but lapsed after June 2025.
Table 2. Manifest code presence *: Australian water and climate policies/strategic plans and DC.
Table 2. Manifest code presence *: Australian water and climate policies/strategic plans and DC.
Gov’t
Level		DocumentData CentreWater Supply or UseWater Availability or DroughtWater SecurityWater
Scarcity		Water Potability/Drinking
FederalNational Climate Resilience & Adaption Strategy 2021–2025-√√√-√
National Water Agreement--√√--
Australian Government Net Zero√-----
State **
ACT		ACT Government Water Strategy--√√√√
ICON Water Climate Change Adaption Plan--√√--
NSWGreater Sydney Water Strategy--√√-√
NSW Climate Change Policy Framework--√---
Climate Change (Net Zero Future) Act 2023------
Net Zero Plan Stage 1 2020–2030-√----
QLDSoutheast QLD Water Security Program--√√√-
Queensland Water Strategy---√√-
Pathways to a Climate Resilient Queensland-√√--√
VICClimate Change Strategy-√----
Water Cycle Climate Change Adaption Plan-√√√-√
Greater Melbourne Urban Water & System Strategy
WAClimate Policy-√√√--
Waterwise Action Plan-√√--√
Notes: * Data code presence is indicated by “√” in the corresponding column. ** State abbreviations: Australian Capital Territory (ACT), New South Wales (NSW), Queensland (QLD), Victoria (VIC), and Western Australia (WA).
Table 3. Current Australian legislation governing water.
Table 3. Current Australian legislation governing water.
StateDocumentData CentreWater Supply or UseWater Availability or DroughtWater
Security		Water ScarcityWater Potability/Drinking
CanberraPlanning and Development Act 2007; 2023 -√-√--
NSWEnvironmental Planning & Assessment Act 1979; 2025 -√-√-√
VictoriaPlanning & Environment Act 1987; 2025 -√-√--
QueenslandPlanning Act 2016; 2025 -√-√--
Western AustraliaPlanning & Development Act 2005; 2025-√----
Note: Keyword presence is indicated by “√” in the corresponding column.
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Ragusa, A.T.; Crampton, A. Clicking and Swiping Away: Hidden Implications of Australian Data Center Water Security and Management. Water 2026, 18, 136. https://doi.org/10.3390/w18020136

AMA Style

Ragusa AT, Crampton A. Clicking and Swiping Away: Hidden Implications of Australian Data Center Water Security and Management. Water. 2026; 18(2):136. https://doi.org/10.3390/w18020136

Chicago/Turabian Style

Ragusa, Angela T., and Andrea Crampton. 2026. "Clicking and Swiping Away: Hidden Implications of Australian Data Center Water Security and Management" Water 18, no. 2: 136. https://doi.org/10.3390/w18020136

APA Style

Ragusa, A. T., & Crampton, A. (2026). Clicking and Swiping Away: Hidden Implications of Australian Data Center Water Security and Management. Water, 18(2), 136. https://doi.org/10.3390/w18020136

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