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HML SERVICES LTD  ·  INFRASTRUCTURE PHYSICS SERIES  ·  PAPER I
White Paper · V4.2 · June 2026

SURVIVING
THE SURGE

AI infrastructure at scale without breaking the planet. AI does not fail for lack of ambition; it fails when physical limits are ignored. Success in 2026 belongs to operators who solve physics, not those who optimise spreadsheets.
Helder Lira · Managing Director, HML Services Ltd
Version 4.2 · June 2026 · Hong Kong
hmlservices.biz · hlira@hml-services.com
Companion: The Orbital Mirage (Paper II, June 2026) examines the proposed off-planet escape from the constraints documented here.
HML Services Ltd · Surviving the Surge · V4.2 · June 2026hmlservices.biz

Executive Summary

Artificial intelligence is scaling faster than the physical systems that support it. The central constraint on AI growth in 2026 is time-to-power: the ability to secure electricity, cooling, land, permits, and social licence fast enough to deploy responsibly.

Compute capacity, model complexity, and inference demand continue to accelerate, while power generation, grid connections, water availability, and permitting move at infrastructure speed. The US interconnection queue stands at approximately 2,600 GW as of early 2026, up from 2,300 GW in January. Berkeley Lab now projects data centres could consume 6.7 to 12 percent of total US electricity by 2028 — pulling the upper-bound demand case forward relative to earlier 2030 framing.

~2,600 GW
US interconnection queue, early 2026 · up from 2,300 GW in January and 1,500 GW in 2023
6.7–12%
LBNL projection of US electricity consumed by data centres by 2028 · two years ahead of prior 2030 estimate
38–73B gal
Projected US data-centre direct water consumption by 2028 · from a measured 17.4B gallons in 2023

Water has moved from a regulatory barrier to a measured and increasingly politicised operating constraint. Community opposition has evolved from reputational friction to capital friction.

The thesis is unchanged and stronger for being stress-tested: scaling AI without breaking the planet is not only possible — it is becoming a competitive advantage.
Evidence Note · V4.2
All figures in this paper are classified as measured baselines, modelled projections, or strategic interpretation. Measured baselines describe observed conditions at a defined point in time. Modelled projections describe plausible ranges, not certainties. Strategic interpretation links those facts to siting, cooling, procurement, and governance decisions. That distinction is not cosmetic — it is how this paper avoids sounding stronger than the evidence base, and how the argument gets harder to dismiss by technically literate readers.
What is new in V4.2

All headline metrics refreshed to June 2026. V4.2 separates measured data from projections; tightens regulatory wording across jurisdictions; strengthens the social-licence argument with explicit capital-methodology definitions; and integrates Figure 1 as a visual anchor for the optimisation-vs-depletion argument. The objective is not a softer paper. It is a more precise, more defensible, and therefore more effective one.

HML Services Ltd · Surviving the Surge · V4.2 · June 2026hmlservices.biz

1The Scale Problem Has Accelerated

In five months, the constraint set has not materially eased in the main markets that matter. It has tightened where it is measured, and in some cases the pace of tightening appears faster than operator planning cycles.

MetricJan 2026 EditionJune 2026 UpdateDirection
US grid interconnection queue2,300 GW~2,600 GW▲ Worsened
US data-centre share of electricity4%, heading to 12% by 20306.7–12% projected by 2028 (LBNL)▲ Accelerated
PJM connection reality8+ year timelinesCycle 1: ~220 GW applied; ~3 GW connected in all of 2025▲ Worsened
Water baselineRegulatory barrierMeasured baseline plus scenario range▶ Strengthened
Social licenceAnecdotalCapital-at-risk more visible; methodology needs definition▶ Quantified

Critical markets remain under strain. Northern Virginia illustrates the extreme case of electricity concentration and queue pressure. Texas shows the consequences of large-load demand moving faster than planning assumptions. Singapore is directly relevant to APAC operators: it combines a tight reserve margin, water stress, and a tropical cooling penalty inside a small, highly regulated system.

Electricity access remains the schedule driver. The stronger framing for V4.2: in leading AI infrastructure markets, queue depth, time-to-power, and grid integration friction are the real deployment bottlenecks — not compute availability, not model readiness.

APAC note

Singapore's constraint set — 6% reserve margin, tropical cooling climate, water stress — is a useful stress-test for the whole region. The markets most exposed to V4.1-style thinking are those where planners still treat power as a solved problem.

HML Services Ltd · Surviving the Surge · V4.2 · June 2026hmlservices.biz

2Water: From Barrier to Measured Constraint

January's edition treated water mainly as a permitting issue. June's evidence shows that was too narrow. Water is now a measurable operational variable, a planning constraint, a public-policy issue, and in some locations a potential litigation trigger.

2.1 The Measured Baseline

US data centres directly consumed 17.4 billion gallons in 2023, and published projections place 2028 direct consumption in a 38 to 73 billion gallon range. That difference matters. The baseline is measured. The forward number is a scenario envelope. They carry different epistemic weight and should never be written as though they are equivalent.

17.4B gal
Measured US direct consumption, 2023 · baseline, not a projection (EPA / LBNL)
38–73B gal
Projected US consumption by 2028 · scenario envelope, not a certainty
2 of 3
New US hyperscale campuses since 2022 sited in high or extreme water-stress counties (Bloomberg)

2.2 The Regulatory Wave

Cooling-water discharge, reuse, and water reporting are moving into closer regulatory scrutiny, and operators increasingly face permitting, disclosure, and compliance obligations that vary by jurisdiction. V4.2 avoids overstating regulatory scope: where bills have been introduced but not enacted, the paper says exactly that. Future compliance is framed as "would mandate," not "mandates."

The core claim is preserved and strengthened: water is becoming harder to externalise. The attack surface is removed. That is not a retreat — it is analytical discipline.

2.3 The Engineering Answer

Cooling choice, siting choice, and water context can produce order-of-magnitude differences in water intensity. Water Usage Effectiveness belongs in the boardroom because the constraint is now strategic, not merely technical. Evaporative cooling in a high water-stress county is not just an operating decision — it is a permitting, reputation, and potentially legal-risk decision.

2.4 Figure 1 — Optimisation vs. Depletion

Figure 1: Data centre displaying Optimization +280% Efficiency while a person kneels in cracked, dry earth with an empty water container
Figure 1. Efficiency gains inside the data centre do not automatically translate into lower physical impact. Without constraints on siting, water, and allocation, efficiency can reduce unit cost while increasing total system pressure. An optimisation narrative that ignores allocation and physical context does not eliminate impact — it displaces it.
HML Services Ltd · Surviving the Surge · V4.2 · June 2026hmlservices.biz

3The A+ Pathway

The A+ Pathway remains one of the most useful parts of the paper. It works because it treats the problem as a system rather than a technology shopping list.

3.1 Five Pillars

1
Appropriate Siting. Select locations on power availability, grid strength, water resilience, and permitting risk. In V4.2, county-level water-stress classification is a hard gate for water-intensive designs — not a weighting factor.
2
Grid-Aware Architecture. Design facilities to align with grid constraints and support demand shaping. With long queue timelines and growing load competition, flexibility is one of the few purchasable schedule accelerators.
3
Power Strategy as Core Competency. PPAs, storage, utility relationships, and demand management are no longer procurement functions. They are deployment strategy.
4
Liquid and Low-Impact Cooling. Match cooling strategy to climate, water availability, and density. The engineering spread is vast, and the policy consequences of choosing badly are larger than before.
5
Unified Measurement. Anchor claims to PUE, WUE, carbon intensity per job, and where possible hourly-matched energy and location-specific water context. Disclosure legislation is converting this pillar from best practice into compliance.

3.2 Benchmarks

FacilityApproachPUEg/kWh CO₂eL/kWh Water
Google Mayes CountyAI-controlled HVAC + 24/7 wind PPA1.061550.2
Meta PrinevilleGeothermal + dry cooling1.0900.02

Benchmark values are from public operator disclosures. They are indicative of engineering direction, not strict like-for-like comparisons across identical reporting boundaries.

3.3 Implementation Roadmap

HorizonAction
0–6 monthsPublish open carbon and water ledgers with transparent boundaries.
6–18 monthsPilot high-density low-water cooling in specific constrained markets.
18–36 monthsSecure hourly-aware clean-power arrangements and utility-aligned load strategies.
36–60 monthsEvaluate nuclear-linked campuses and other firm low-carbon options as strategic horizons, not base-case implementation steps. Commercial SMR deployment remains an early-2030s proposition.
HML Services Ltd · Surviving the Surge · V4.2 · June 2026hmlservices.biz

4The Misallocation Crisis and the Carbon Math

Most AI infrastructure commentary asks how to supply more compute. This paper asks what the compute is for. That remains the right question.

The workload structure has inverted: training dominated compute in 2020–2022; by 2024–2026 inference dominates at 60–70% and grows at roughly 122% CAGR. Enterprise budget allocation (BCG, 2025) places support functions at 38%, operations at 23%, marketing and sales at 20%, R&D at 13%, and climate-critical applications below 3%.

<3%
Share of enterprise AI compute serving climate-critical applications (BCG, 2025)
5–10%
Global GHG emissions AI could mitigate by 2030, if compute were allocated to it (Google/BCG)
~15 Mt CO₂e
Global AI training emissions, 2024 · single large-model training ≈ 500 t CO₂e

Efficiency gains reduce energy intensity per unit of compute, but observed demand growth can absorb those gains and increase total system load — especially in inference-heavy markets. V4.2 frames this as an interpretive risk, not a mechanically proven law for every workload. The Jevons dynamic is a serious structural warning, not a certainty.

Once power, water, and permitting become rate-limiting factors, compute allocation stops being only a software-market choice. It becomes an infrastructure-governance question.

The enterprise allocation argument is portfolio governance: if scarce infrastructure is being allocated to low-social-value workloads, then compute allocation becomes an infrastructure policy question — not merely a product-market outcome. That is the conversation the industry has not yet held.

HML Services Ltd · Surviving the Surge · V4.2 · June 2026hmlservices.biz

5Social Licence: From Sentiment to Capital Friction

This section is right on the substance and stronger with tighter method. V4.2 fixes the method.

Opposition now has measurable economic weight. Delays, local resistance, moratorium proposals, tax debates, and utility bill impacts have moved beyond public-relations nuisance. They are now part of project bankability and delivery risk. But headline figures need explicit methodology before they can anchor a serious argument.

Required Methodology Note — Capital-at-Risk Figures

Any blocked-capital headline (e.g. US8 billion) must define: (1) What counts as blocked, delayed, cancelled, or proposed. (2) Source hierarchy — primary filings, operator announcements, secondary reporting. (3) Treatment of overlapping announcements. (4) Geographic scope and time window. (5) Whether values are nominal announced capex, estimated project value, or another proxy. Without this box, a sceptical reader does not need to refute the thesis — they only need to question one number.

5.1 Constraint Summary — June 2026

ConstraintJune 2026 StatusImpact
Grid interconnection~2,600 GW queued; PJM ~220 GW applied vs ~3 GW connected (2025); ERCOT 410 GW large-load queuePrimary schedule driver
WaterMeasured baseline established; rising policy scrutiny; growing permitting and litigation exposurePermitting and litigation risk
AI power growthLBNL projects 6.7–12% of US electricity by 2028, ahead of prior 2030 framingConsumer bill and system planning pressure
Social licenceOpposition increasingly legible in legislation and project outcomes; capital metric useful but must be definedCapital-at-risk and approval friction

The strategic conclusion strengthens with each data point: transparent engagement is now an approval prerequisite. Operators who treat social licence as communications rather than engineering are funding the case studies for the next legislative wave.

HML Services Ltd · Surviving the Surge · V4.2 · June 2026hmlservices.biz

6What Changed: January to June 2026

1
The queue kept growing. National and regional data continue to show deep interconnection backlogs, while realised project connection remains slow. Time-to-power stays the central bottleneck in leading markets.
2
Water moved from barrier to baseline. Direct consumption is now discussed in measured terms. The policy environment is shifting from passive concern to active scrutiny — permitting, disclosure, and in some cases revocation.
3
The demand curve pulled forward. Berkeley Lab's 2028 range places the upper-bound power case two years earlier than the framing in January's edition. Operator planning cycles have not caught up.
4
Opposition acquired a balance-sheet dimension. The argument is now economically legible. V4.2 explicitly defines the capital methodology before using any headline figure — that discipline is what makes the argument stick.
5
The escape-hatch narrative expanded. That remains handled in Paper II: The Orbital Mirage. That is the right structural choice — keeping terrestrial constraints sharp in Paper I.
Editorial Recommendations — Three Structural Improvements

1. Uncertainty protocol at the front. Distinguish measured baselines, scenario projections, and strategic inference. A short note is enough, but it must be explicit.
2. Methodology note for social-licence figures. Without it, critics bypass the thesis and attack the number.
3. Reserve hard declarative language for directly observed claims. The paper is strongest when it sounds like a disciplined operator, not an activist with good graphics.

AI does not fail for lack of ambition. It fails when physical limits are ignored. That is the real upgrade from V4.1 to V4.2. Not a softer paper. A harder one.
HML Services Ltd · Surviving the Surge · V4.2 · June 2026hmlservices.biz

Data-Source Reference Pack

Energy and Grid

US DOE / LBNL interconnection and demand reports (2024–26) · queue ~2,600 GW early 2026; data centres 6.7–12% of US electricity by 2028.

PJM Interconnection (2025–26) · Cycle 1 intake ~220 GW (Apr 2026); ~103 GW agreements since 2020, ~23 GW in service; 74% withdrawal; wholesale costs +54% in one year.

ERCOT / Ascend Analytics (2026) · 410 GW large-load queue, 87% data centres; 198 GW applied Q1 2026.

Goldman Sachs (2024); IEA Energy & AI (2024) · global data-centre electricity 415 TWh (2024) → 945 TWh (2030).

Water

EPA / Shehabi et al., LBNL (2024–25) · US direct consumption 17.4B gal (2023); 38–73B gal projected 2028; hyperscale ~half.

Texas analyses (2025–26) · TWDB 399B gal/yr projection by 2030; SB 7 active.

IEA (2025–26) · global data-centre withdrawals >1,200B litres/yr by 2030.

Bloomberg (May 2025) · two-thirds of new US hyperscale campuses since 2022 in high/extreme water-stress counties.

Regulatory (2026) · EPA NPDES cooling-tower discharge rules; Data Center Water and Energy Disclosure Act (Mar 2026, introduced not enacted); Google Chile partial permit revocation.

Cooling and Carbon

LBNL (2022) · evaporative 1.8–2.6 L/kWh. Immersion (2023–24) · 0.05–0.10. Meta Prineville · 0.02 L/kWh, zero carbon. Google Mayes County · PUE 1.06, 155 g/kWh, 0.2 L/kWh.

Google/BCG (2023) · AI mitigation potential 5–10% of global GHG by 2030.

Workloads and Allocation

BCG (2025) · enterprise allocation: support 38%, ops 23%, marketing/sales 20%, R&D 13%, climate-critical <3%.

IDC (2025) · AI infrastructure spend 2B Q2 2025, +166% YoY. a16z (2025) · ChatGPT 800M weekly users.

Social Licence

Data Center Watch (2025) · US8B blocked/delayed Mar–Jun 2025 (see methodology note, Section 5). Multistate (2026) · 300+ bills, 30+ states.

Bloomberg (2026) · Virginia data centres ~40% of state consumption (2024).

Companion Paper

Lira, H. (2026). The Orbital Mirage: Environmental Externalities of Space-Based AI Infrastructure and the Limits of Off-Planet Escape. HML Services Ltd, Infrastructure Physics Series, Paper II, June 2026.

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