Markets / Chicago
C&W 2026 Americas · Primary #5 · updated 2026-11-05
Chicago
There's no state incentive for new deals, a city moratorium is drafted, and ComEd is demanding money up front. The queue shrinking from 39 to 25 GW is healthy, but the economics of new Illinois builds just got worse.
coolingGrid: ComEd (Exelon, PJM)
CBRE H1 2026: 910.6 MW inventory, 2.2% vacancy [Cushman & Wakefield, 2026 Global Data Center Market Comparison (Americas rankings) (2026-05); CBRE press release: demand continues to outpace supply (H1 2026 market table) (2026-08); Data Center Frontier: CBRE record construction fails to ease capacity crunch (2026-08)]
Power and the queue
- ComEd's large-load development queue is about 25 GW, down from roughly 39 GW in late 2025. Six transmission security agreements are backed by over $1B in letters of credit, and deposits now cover transformers and substations. A proposed non-firm interruptible large-load tariff awaits an ICC decision expected in Q1 2027. [ComEd: secures over $1 billion in financial commitments from large load projects (2026-09-16)]
- ICC opened an investigation (Mar 20, 2026) into tariff and cost-allocation protections for large loads. [Illinois Commerce Commission: data center tariff investigation press release (2026-03-20)]
- CBRE H1 2026: 170.3 MW under construction, over 90% preleased. [Data Center Frontier: CBRE record construction fails to ease capacity crunch (2026-08)]
Notable projects owners where public
No verified public item yet. This is a gap we are working on.
Regulatory posture incentives, moratoria, zoning, water, large-load rules
- Illinois paused new Data Center Investment Program applications from Jul 1, 2026 (governor directive of Jun 5) with no end date. Prior agreements are honored. [Gov. Pritzker pauses new data center tax incentives (2026-06-05); Illinois DCEO: Data Center Investment tax exemptions and credits (2026-11-05)]
- Chicago: a mayoral executive order (Aug 11, 2026) created enhanced review. A proposed 12-month moratorium was introduced Sep 23 and sits in the Rules Committee without a hearing. [City of Chicago: Mayor Johnson signs executive order creating enhanced review for data cen (2026-08-11); City of Chicago: Mayor Johnson and Council members introduce data center moratorium ordina (2026-09-23)]
- Nov 3, 2026 ballots: voters said no to permitting data centers in Joliet (Will Co.) and several Madison County townships. Bloomington passed an advisory moratorium. [DCD: Local data center moratoria, limits, and restrictions voted in across the US (2026-11-04)]
Pending legislation and actions 12 items
| Date | Jurisdiction | Item | Status | Impact | Source |
|---|---|---|---|---|---|
| 2026-09-23 | Chicago city | Proposed 12-month moratorium ordinance Would pause new data centers and major expansions. Referred to Rules with no hearing yet. | pending | high | [City of Chicago: Mayor Johnson and Council members introduce data center moratorium ordina (2026-09-23)] |
| 2026-06-17 | Illinois state | SB4004 (Aquifer Protection Act) Creates Data Center Water Transparency and Aquifer Protection Act; bars data centers from using Mahomet Aquifer water beginning 2027; bars permits for Mahomet withdrawals; requires existing users to transition by 2028; bans local nondisclosure clauses restrict | pending | low | [SB4004 Bill Status - Illinois General Assembly] |
| 2026-05-30 | Illinois state | SB4016 (Hyperscale Data Centers / POWER Act) Comprehensive hyperscale data center regulation: cumulative impact review, public notice, community benefit agreements, NDA restrictions, water-impact permits, quarterly water reporting, water scarcity plans, energy and water reporting to ICC, hyperscale self- | pending | low | [SB4016 Bill Status - Illinois General Assembly] |
| 2026-05-27 | Illinois state | HB5513 (Hyperscale Data Centers / POWER Act companion) House companion to SB4016 with environmental, water, energy, public-benefit, reporting, and solar permitting provisions. | pending | low | [HB5513 Bill Status - Illinois General Assembly] |
| 2026-05-22 | Illinois state | SB2181 (Data Center Reporting) Creates Illinois Data Center Energy and Water Reporting Act; annual energy and water reporting to IPA; IPA ratepayer-impact study; confidentiality, public access, enforcement, and penalties. | pending | low | [SB2181 Bill Status - Illinois General Assembly] |
| 2026-05-22 | Illinois state | SB3120 (DCEO-Data Centers) Conditions data center incentive qualification on water stewardship strategy disclosure and requires DCEO reporting on recipient water stewardship strategies. | pending | low | [SB3120 Bill Status - Illinois General Assembly] |
| 2026-05-22 | Illinois state | SB3761 (Data Centers-Various) Establishes data center self-direct clean energy program, 180-day preconstruction disclosure to ICC, public meeting requirements, water-use disclosures to DNR, penalties up to $10,000 per violation, and utility tariff review. | pending | low | [SB3761 Bill Status - Illinois General Assembly] |
| 2026-05-22 | Illinois state | SB3830 (Data Centers-Various) Similar clean energy self-direct and utility tariff framework; adds water discharge pollutant identification, DNR water-use disclosure, Water Use Act changes, and groundwater emergency provisions. | pending | low | [SB3830 Bill Status - Illinois General Assembly] |
| 2026-01-14 | Illinois state | HB4319 (Data Center-Property Rights) Creates a compensation framework for property owners within 1,000 feet of a data center for value loss, business revenue loss, or adverse impacts such as noise, vibration, traffic, stormwater burden, or lighting; limits concurrent home-rule powers. | pending | low | [HB4319 Bill Status - Illinois General Assembly] |
| 2025-06-02 | Illinois state | HB3574 (Procurement-Data Residency) Requires state data storage contracts to keep data in the United States and creates bid credits for Illinois and opportunity-zone storage, including data center-related provisions. | pending | low | [HB3574 Bill Status - Illinois General Assembly] |
| 2025-06-02 | Illinois state | SB2290 (Use/Occ Tx-Quantum Computing) Expands the state data center definition for incentive purposes to include a quantum research facility. | pending | low | [SB2290 Bill Status - Illinois General Assembly] |
| 2025-04-03 | Illinois state | SB0094 (Data Centers-Foreign Ownership) Confirmed via ILGA synopsis: creates the Data Center Construction by Foreign Adversaries Act; bars a foreign-adversary-controlled company from constructing a data center in Illinois unless ICC, IPA, and DCEO jointly certify load conditions. | pending | low | [SB0094 Bill Status - Illinois General Assembly] |
In force / enacted 10 items
| Date | Jurisdiction | Item | Status | Impact | Source |
|---|---|---|---|---|---|
| 2026-11-03 | Joliet; Chouteau, Granite City, Nameoki and Venice Twps (Madison Co.) city | Nov 3, 2026 ballot measureuncertain Advisory questions: voters said officials should not permit data centers. | enacted | high | [DCD: Local data center moratoria, limits, and restrictions voted in across the US (2026-11-04)] |
| 2026-10-09 | PJM (13 states + DC) utility | FERC order ER26-3515: PJM Large Load definition and registry FERC accepted the definition and registry, effective Oct 12, 2026, and rejected the rest of the filing. The registry is not a public per-request queue. | enacted | high | [FERC order ER26-3515 on PJM Large Load definition and registry (2026-10-09)] |
| 2026-09-16 | Gary city | Executive Order signed by Gary Mayor Eddie D. Melton on 2026-09-16, pausing approval of new data center development in the city Mayor issued a one-year executive-order moratorium on new data center development Duration: One year from the executive order | in force | high | [https://gary.capitalbnews.org/gary-data-center-moratorium/] |
| 2026-09-08 | Lake County county | Lake County Ordinance 26-1018, amending Chapter 151 (Unified Development Ordinance) of the Lake County Code of Ordinances to define and impose a temporary moratorium on data centers in unincorporated Temporary pause while the County studies infrastructure, environmental, and community impacts and develops a regulatory framework, which officials say could serve as a resource for surrounding communities. Duration: Eight-month moratorium on data centers in un | in force | high | [https://www.shawlocal.com/lake-county-journal/2026/09/08/lake-county-oks-temporary-morator] |
| 2026-07-20 | City of West Chicago city | City of West Chicago Ordinance 26-O-0011 Duration: 180-day moratorium on receipt, processing, and final approval of applications and permits for data centers and battery energy storage systems in every zoning district; protects complete pre-effective-date applications and approved permits, includes l | in force | high | [City of West Chicago] |
| 2026-06-05 | Illinois state | Governor directive: pause Data Center Investment Program DCEO stopped processing new data center incentive applications and agreements on Jul 1, 2026, with no stated end date. Pre-Jul 1 agreements are honored. | in force | high | [Gov. Pritzker pauses new data center tax incentives (2026-06-05)] |
| 2026-05-26 | Merrillville (Lake County) town | Town Council vote (7-0) imposing a one-year moratorium on data center project approvals; ordinance or resolution number not captured in sources reviewed Town Council voted 7-0 to impose a one-year moratorium on data center project approvals; the town also held a June 11, 2026 educational meeting. Duration: One year, June 1, 2026 through May 31, 2027 | in force | high | [Town of Merrillville, Indiana (2026-05-26)] |
| 2026-04-21 | Plainfield village | Village of Plainfield ordinance establishing a 180-day moratorium on data centers and computing-infrastructure warehouses (specific ordinance number not published in sources reviewed) Pause to allow staff, elected officials, and consultants to study best practices and develop a new unified development ordinance addressing data centers. Duration: 180-day moratorium on the receipt, processing, approval, and permitting of applications for data | in force | high | [https://patch.com/illinois/plainfield/data-center-moratorium-imposed-plainfield-after-unan] |
| 2026-09-16 | ComEd utility | Large-load deposits and transmission security agreements Over $1B in financial commitments collected. The queue fell to about 25 GW from about 39 GW, and the ICC is investigating a tariff framework. | in force | medium | [ComEd: secures over $1 billion in financial commitments from large load projects (2026-09-16)] |
| 2026-08-11 | Chicago city | Mayoral executive order: enhanced data center review Creates enhanced regulatory review and a task force, and calls for a Council moratorium. | in force | medium | [City of Chicago: Mayor Johnson signs executive order creating enhanced review for data cen (2026-08-11)] |
Pricing & supply snapshot directional
MW Desk estimate / directional range, Q4 2026
Asking-rate bands below are MW Desk directional estimates in USD per kW-month. They are rounded ranges, not quoted rates, and they go stale quickly.
- Retail colo (roughly 0–250 kW): $155–405/kW-mo
- Wholesale (roughly 250 kW–4 MW): $100–220/kW-mo
- Large / hyperscale blocks (roughly 4 MW+): $100–220/kW-mo
- Vacancy band: roughly 2–4% (tight)
- Commissioned inventory (directional): ~1.5–2.0 GW
- Available power (directional): ~20–55 MW
- Under construction: ~25–60 MW
- Planned pipeline: ~4.7–5.2 GW
- Absorption: strong positive absorption
- Power / timing: Near-term wholesale blocks are limited; most near-term MW is spoken for or pre-leased.
Indicative only. Ranges are rounded and adjusted directional estimates, not quoted asking rates or a survey. Confirm with brokers and operators before acting. Source data ages quickly.
TJ field notes
Coming soon: TJ's on-the-ground notes on this market. Expect what the queue really looks like, which sites can actually get power, and what the brokers aren't saying.
Slot reserved for TJ's detailed market report.