US data center construction: Most projects for 2027 are already under construction; 2028 depends on Texas permits

Why is 2027 relatively secure and 2028 more sensitive?

In the top 20 US states covered by the SemiAnalysis model, roughly three-quarters of the 33.8 GW of capacity scheduled for delivery in 2027 is already under construction. The firm therefore maintains its forecast of more than 50 GW in new capacity worldwide that year.
By contrast, the model forecasts 62.2 GW of net additions in the US in 2028, most of which has yet to begin construction; projects must still advance through approvals, power engineering and construction. The 13 states tracked in the report account for a combined 43.5 GW, or about 70% of the national forecast.
An expansion of restrictions does not mean all corresponding capacity will be delayed. In September, the firm estimated that only 1.5 GW of the roughly 20 GW of capacity subject to local restrictions faced delays; many projects already have permit protections or do not need the affected approvals before the suspension ends.

Texas accounts for nearly 30% of the model's US net capacity additions in 2028. In August, the state suspended the progression of projects through the grid interconnection process, and in September it froze environmental permits for data center applications, also affecting onsite generation projects that had previously been able to proceed.
The start of construction does not mean the power phase has been approved. The report cites two campuses under construction whose principal generation permits are still awaiting approval; if the stoppage exceeds the schedule buffer for power engineering, servers could already have arrived while the power needed to operate them is still unavailable.
The state grid operator plans to submit an audit report on 10 December, but permitting will not automatically restart as a result. A water-use review, a decision to resume issuing permits and approval of individual applications are still required. If permitting restarts around December, some projects may be able to absorb the brief interruption; if the suspension continues through the regular 2027 legislative session, the freeze will have lasted about 8 months from September.
The 16.7 GW of planned capacity in Texas listed in the report represents exposure to policy changes, not expected delayed capacity. A longer or broader freeze would require a project-by-project assessment of which permits are still needed.

Of the 20 gubernatorial candidates counted in the report, 9 support a pause on new construction and the remaining 11 support additional conditions; the positions span both parties. A pause directly holds up projects that still need approvals. Additional conditions may allow developers to proceed by funding grid upgrades, adjusting cooling designs or signing community agreements, but add cost and time.
In one election scenario, if candidates advocating a pause win in each state, those states together have about 30 GW of capacity planned for 2028; if candidates favoring fewer restrictions win, that exposure falls to 5.7 GW. The amount actually delayed depends on the permits projects still need, the duration of any pause and how policies are ultimately implemented.
Even if the side favoring fewer restrictions wins, the development environment may become more demanding: tax incentives may decline, upfront commitments may increase, and developers may find it harder to pass infrastructure costs on to other utility customers.

Ohio is expected to add 5.1 GW in 2028, and most has yet to begin construction. Both gubernatorial candidates support some form of conditional delay: one would allow projects that meet conditions to proceed, while the other advocates stopping all new approvals until legislation is passed, potentially leaving affected projects waiting together for a political agreement.
Oregon has suspended the processing and issuance of certain air and water discharge permits for new or expanded data centers until 1 July 2027; applications may still need to complete technical review after the suspension ends.
SemiAnalysis expects stricter federal cost-allocation rules to affect mainly project economics and financing: developers may need larger upfront payments or more collateral, delaying some projects; related permitting reforms could speed up construction of supporting infrastructure.
Although large cloud providers are better able to bear costs and power expenses, projects still need permits, equipment and timely power supply. Building in another state also requires power, approvals and construction schedules to be realigned.