Three things to know
You do not need to know anything about zoning to use this guide. Read these three facts, then follow the numbered pages on the left (or the chips above on a phone). Pages 2 to 8 follow the six subjects of the Mayor's Executive Order No. 3-2026, with the first two subjects, land use and City infrastructure, as this study's primary focus (the executive order lists them first but does not rank the six). Each page ends with a button to the next one.
Memphis has no rule written for data centers.
The Unified Development Code (UDC), the zoning and development rules the City and County adopted together, never mentions them. So when one is proposed, the Zoning Administrator (planning staff) has to decide which existing category it fits.
If it counts as an office, in most districts there is no public hearing: the Zoning Administrator decides its site plan.
Offices are permitted by right in every mixed-use and industrial zoning district under the base use table (some overlay and special purpose districts have their own lists). The Zoning Administrator must approve, approve with conditions, or deny the site plan within ten working days of a complete application, unless it needs City or County Engineering or Technical Review Committee review. That is one step, not the whole project: building, utility and other permits still follow. At that step there is no mailed notice and no elected official votes, unless the decision is appealed: the owner and property owners within 1,000 feet may appeal, and an appeal brings a hearing and mailed notice; in RU-3, RU-4 and RU-5 an office needs a special use permit with a hearing instead.
On October 20 the City Council rejected an 18-month moratorium and passed a 135-day temporary pause.
The vote on the moratorium (Ordinance 5982) tied 6 to 6, so it failed. The temporary pause (Substitute Ordinance 5986) passed 7 to 5. As posted, it stops new applications and City approvals (zoning changes, special use permits, site plans, building permits) for new data centers for 135 days; existing data centers keep operating. On October 21 the Council's attorney circulated a copy labeled “ADOPTED” whose operative text matches the posted version (only its sponsor line differs, naming Logan alone), but it has no signature, attest or effective date, so the start and end dates are still unknown; the pause can end no earlier than March 4, 2027. The pause ends 135 days after it takes effect, or sooner if permanent data-center rules take effect first.
Blue means "permitted by right." Brass means "special use permit: a public hearing, then a vote." Grey means "not permitted." When you see a small label like checked against the UDC itself, it tells you how sure we are. Switch on Show where each fact comes from at the top to see the exact section behind every statement.
Data center: a building full of servers, the computers behind apps and online services; the UDC does not yet define it as a use.
Unified Development Code (UDC): the zoning and development rules the City of Memphis and Shelby County adopted together; it lists what may be built in each zoning district.
Zoning district: an area of land the UDC places under one set of rules, such as IH (heavy industrial) or RU-3 (urban residential).
Permitted by right: allowed in that zoning district without a public hearing or a vote; a site plan and ordinary permits are still required.
Site plan: the drawing of a proposed project that the Zoning Administrator approves, approves with conditions, or denies.
Zoning Administrator: the planning official the UDC names to decide site plans; part of the Division of Planning and Development (DPD).
Special use permit: a case-by-case approval: mailed notice to nearby property owners and registered neighborhood groups, a Land Use Control Board public hearing, then a City Council (or County Commission) vote that can attach conditions.
Land Use Control Board: the joint City–County board that holds public hearings on zoning matters and makes recommendations to the City Council and the County Commission.
Executive Order No. 3-2026: the Mayor's order of October 9, 2026, which starts a 90-day study of rules for large data centers.
Temporary pause: the 135-day stop on new data-center applications and City approvals in Substitute Ordinance 5986; the 18-month moratorium (Ordinance 5982) failed.
The 90-day study: what the Mayor asked for
On October 9, 2026 the Mayor signed Executive Order No. 3-2026. It gives a study group chaired by the City's Chief Operating Officer ninety days to recommend policy guardrails for large and hyperscale data centers across six subjects. It also orders City Engineering to add a review period of at least five business days to its permitting process during the study, and it says plainly that it does not pause or delay the City Council. Everything in this guide is organized around those six subjects, with the first two as this study's primary focus; the executive order itself does not rank them.
Land use and zoning
What the UDC allows today, and what a data-center definition, district list and review path would change. See pages 3, 5, 6 and 8.
City infrastructure standards
Traffic impact studies, stormwater, sewer capacity and the ordered engineering review of at least five business days. See pages 4 and 8.
Air quality
The executive order says the City lacks authority over “certain matters, such as air quality.” The Shelby County Health Department issues the permits, and the 2025 turbine-permit appeal was filed under City Code sec. 16-71 with the joint Memphis and Shelby County Air Pollution Control Board. See page 4.
Water and the aquifer
Who permits wells, what an MLGW customer does and does not need, and where the City has no step today. See page 7.
Energy and utility cost responsibility
No UDC or City standard says who pays for grid upgrades, but a 2026 state law (Public Chapter 961) now does in part. The new data-service tariff of Memphis Light, Gas and Water (MLGW) sets rates and contract terms for large data-service customers but does not itself assign grid-upgrade costs. MLGW's governance page names the City Council as the rate-setting body for the utility; the Tennessee Valley Authority (TVA) supplies wholesale power. See page 4.
Noise
There is no numeric decibel limit for a stationary use like a data center, though the City's noise ordinance (Memphis Code Chapter 9-68), a general ban on unreasonably loud noise, applies. The UDC's only numeric limit is for wind energy systems. See page 6.
Recommendations are due about January 7, 2027 (October 9 plus ninety days). The executive order's own wording governs the deadline.
Where a data center can be built today
Memphis is divided into zoning districts, and each district has a list of what may be built there. Because data centers are not on any list, the Zoning Administrator decides which listed category they resemble. Choose a category below, then tap a district to see whether a data center would be allowed there and what rules it would have to follow.
Tap a district above
The 29 zoning districts are grouped by type. The industrial districts (EMP, WD and IH) are where most large sites would be.
Who is in charge of what
The Mayor's study covers six subjects. Some are the City's to decide alone, some it shares with Shelby County, and some belong to MLGW, TVA or the State. A blue dot means that body makes the rule today. A brass dot means it shares the job.
MLGW is Memphis Light, Gas and Water, the City-owned utility. TVA is the Tennessee Valley Authority. In the source lines, SCHD is the Shelby County Health Department and TDEC is the Tennessee Department of Environment and Conservation, the State environmental agency.
How a rule gets changed
There are two routes. Route A changes the text of the UDC, and because the City and the County adopted the UDC together, both the City Council and the County Commission must vote. Route B decides one project at a time with a public hearing. Route B already applies today wherever the use table lists the use as a special use: if a data center is read as an office, a site in RU-3, RU-4 or RU-5 needs one, and some other readings need one in other districts (see page 3). The option under study would require a special use permit for every data center, wherever data centers are allowed. Flip the switch to see the difference.
Route A · Text amendment (UDC Chapter 9.4): changing the UDC text
Route B · Special use permit (UDC Chapter 9.6): one project, one hearing
How close to homes
Memphis has no setback rule written for data centers. In an industrial district a building can stand 10 feet from a single-family lot line (UDC Sec. 3.10.2.B); the largest separation the UDC sets is 100 feet, for an electrical substation (Sec. 5.3.4.D). Drag the slider to move the building and see which numeric building setbacks, here and elsewhere, it would meet. Substation and ground-equipment distances apply to other objects and are shown for reference only. Meeting a setback is one requirement, not permission to build. No county compared here adopted a 500-foot setback; Loudoun used 500 feet only to decide which pending projects were grandfathered (resolution of March 18, 2025).
How loud it may be at a residential lot line
Memphis has no numeric decibel limit for a stationary use like a data center; the City's noise ordinance (Chapter 9-68), a general ban on unreasonably loud noise, still applies. The only numeric limit in the UDC is for wind energy systems, and Chapter 9-68 also covers noisy vehicles (Sec. 9-68-9) and requires mufflers on stationary engines such as generators (Sec. 9-68-12); no train-noise provision was found. Loudoun County's limits apply day and night, though generator tests are exempt. For scale, 55 decibels is a quiet conversation; 70 is a vacuum cleaner.
Who controls the water
Data centers use water for cooling. In Memphis that water comes from the same underground aquifer as drinking water. A data center that buys water from MLGW, is not making a withdrawal under the state registration rule, so it needs no well permit and no State withdrawal registration. That is the only thing buying utility water changes: the zoning and site-plan steps on page 3, and ordinary utility service, plumbing, sewer and discharge rules, apply whatever the water source. Only a data center that drills its own wells goes through a permit process, run by the Shelby County Health Department and the State, not the City. Pick one to see the steps.
What could change: candidate changes under study
These are the changes the research record supports as options for the City to weigh. None is a City proposal. Each is sorted by what it would take: some are already required, some are existing rules with no public record found yet that they are being applied, and some would be new rules. The three that matter most are a definition with district rules, a minimum distance from homes and schools, and a measurable noise standard.
Fact check
Things people often say about data centers in Memphis, each checked against the original document where one exists. Verified means the document says so. Contradicted means the document says otherwise. Partly verified means part of the statement is confirmed by the document and part is not. Not comparable means the numbers being compared count different things. Reported means only the news says so and the original has not been published. Not yet checked names the record that would settle it.