Eight layers of data center site readiness

Until 2023, the input to layers 3 through 7 was unstructured regulatory text spread across 50 state PUCs, 7 RTOs, federal FERC and EPA dockets, and county zoning codes. Reading it required licensed engineers, environmental attorneys, and former agency staff. The economic unit of work was billable hours, not software seats — and the consultants who hold that knowledge do exceptional work that nobody is trying to displace.

Two things shifted simultaneously. First, LLM ingestion of unstructured technical and regulatory text became viable and cheap. The cost-per-jurisdiction for normalized rule extraction collapsed from roughly $5,000 with traditional NLP pipelines to ~$0.10-2 with frontier models. Second, the post-2025 regulatory landscape introduced novel rule sets that even the consultants are learning in real time: ERCOT Batch Zero / PCLR, FERC Order 2023 and 2023-A queue reform, EPA Title V interim guidance on data center backup generation, state-level data center by-right zoning rollbacks like Loudoun County's in March 2025.

The result is that layers 3 through 7 are newly tractable as software, in a 12-24 month window before horizontal AI generalists notice and enter. Consultants remain the right tool for site-specific judgment and politically sensitive negotiations. Software is the right tool for the cross-jurisdictional pattern-matching, real-time docket tracking, and structured corpus work that is genuinely harder for humans than for LLMs.