City of St. Louis, MO

ShortCommunity fund falls short

A strong version: A fund that scales with the project, with a community seat on the body that spends it

amount: $15,750,000 · cadence: one time · scales with project: yes · community seat: no

$30 per square foot of approved data center development, estimated at $15,750,000 (implying about 525,000 square feet). Timing of payment is not stated. This is a term sheet commitment; the recorded CBA that would make it binding had not been posted as executed as of September 7, 2026.

1. p. 2, Other Community Benefits (Financial). https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/CBA-provisions.pdf “$30 per square foot of approved data center development, an estimated $15,750,000, to a Fund”

ShortClawbacks falls short

A strong version: Incentives come back if the facility stops operating, not only if a jobs number is missed

triggers: jobs, other · proportional: yes

Liquidated damages rather than incentive repayment, since no incentives were given. Revenue: $15,000 per $100,000 shortfall against projected annual tax revenue if not met by 2029. Jobs: $2,000 per job short of 25 in year one, 50 in year two, then 100, for 20 years. No trigger tied to the facility ceasing operation. All of this is term sheet language pending the recorded CBA.

1. p. 1, Tax Revenue & Job Requirements. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/CBA-provisions.pdf “pay $15,000 in liquidated damages for every $100,000 below the projected annual tax revenues if not met by 2029”
2. p. 1, Tax Revenue & Job Requirements. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/CBA-provisions.pdf “pay $2,000 in liquidated damages for each job short of the required total”

ShortDecommissioning falls short

A strong version: A bond, escrow, or letter of credit that pays for teardown and site restoration if the operator walks

instrument: covenant only

A decommissioning plan to remove and recycle e-waste must be filed if the facility is vacant for more than a year. No bond, escrow, or letter of credit.

1. p. 3, Miscellaneous Restrictions. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/CBA-provisions.pdf “file a decommissioning plan to safely remove and recycle electronic waste if the data center is vacant for over a year”

?Grid costs not known

A strong version: The operator pays for its own interconnection and carries a minimum bill that survives it leaving

interconnect paid by: operator · governed by: Ameren Missouri large-load tariff approved by the Missouri Public Service Commission on November 24, 2025 (customers of 75 MW or more; 12-year minimum service term; early exit fees; two years' notice to terminate or reduce load)

The permit requires the petitioner to fund any project-specific additional electrical infrastructure. Any minimum bill comes from the Ameren tariff, not the city deal. Reasonable efforts to reach 50 percent renewable within five years with localized RECs as fallback; PUE of 1.25 or better (1.35 if reusing an existing building) with annual reporting; generators Tier 4 and never a general operating power source; no generator testing on bad air quality days is already among the April 21, 2026 conditions. Press reports that the Board of Adjustment, after an 11-hour hearing that began July 29, 2026, added a requirement for at least 2.4 MW of on-site solar or wind generation.

Softening languageReaching 50 percent renewable within five years is a "reasonable efforts" obligation with certificates as the fallback.

1. p. 2, Energy, Efficiency & Infrastructure Standards. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/Conditional-Use-provisions.pdf “Petitioner must fund any project-specific additional electrical infrastructure”
2. p. 2, Backup Generators. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/Conditional-Use-provisions.pdf “No testing of backup generators on bad air quality days”
3. https://www.stlpr.org/health-science-environment/2025-11-24/missouri-utility-regulators-approve-ameren-rates-data-centers
4. https://www.stlpr.org/health-science-environment/2026-07-30/st-louis-board-allows-data-center-near-armory-to-move-forward-with-new-rules
5. https://www.firstalert4.com/2026/07/31/midtown-armory-data-center-project-approved-after-11-hour-appeals-hearing/

MetWater meets the bar

A strong version: A stated cap or closed-loop cooling, plus public reporting

reporting: yes · cooling: closed loop

Closed-loop system with air-cooled chillers required. Before a building permit, a written agreement with the Water Division to fund all required fees, system impact fees, a hydraulic model study, and the cost of rectifying any detrimental impact on existing customers. Annual water-usage reporting under the CBA term sheet, which may be made public. No volume cap.

1. p. 2, Water Responsibility. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/Conditional-Use-provisions.pdf “Must use a closed loop system and air-cooled chillers to minimize water consumption”
2. p. 2, Utilities and Environment. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/CBA-provisions.pdf “annually report electricity usage, waste heat, and water usage, which may be made public”

?Noise not known

A strong version: A numeric limit measured at the nearest residence or property line

measured at: All adjoining parcel lines, measured in an annual third-party noise report to the Health Director and Zoning Administrator. The standard is the City noise ordinance, not a number in the deal.

Noise-emitting equipment must be fully enclosed in acoustically treated structures placed away from frontages. Generator testing only on weekdays from 10:00 AM to 12:00 PM and 2:00 PM to 5:00 PM. At the appeal hearing, a Saint Louis University biology professor who studies sound testified that low-frequency noise bends around and passes through solid objects and would need about 14 feet of absorptive material to absorb a 20 Hz tone.

1. p. 1, Noise and Vibration Controls, Reporting. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/Conditional-Use-provisions.pdf “annual third-party report of noise emissions taken at all adjoining parcel lines”
2. p. 2, Backup Generators. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/Conditional-Use-provisions.pdf “Testing is strictly limited to weekdays between 10:00 AM–12:00 PM and 2:00 PM–5:00 PM”
3. https://www.yahoo.com/news/us/articles/st-louis-board-upholds-armory-202506410.html

MetJobs meets the bar

A strong version: Binding job commitments with a consequence, not projections

permanent: 100 · construction: 1050 · local hire: yes · prevailing wage: yes · enforceable: yes

Enforceable minimums of 25 median-wage jobs in year one, 50 in year two, and 100 thereafter, for 20 years, backed by $2,000 per job in liquidated damages. The City projects about 200 permanent on-site positions (50 at the data center, 150 in the Armory office). First-Source hiring for entry-level jobs applies to the developer and large tenants. Prevailing wage and M/WBE compliance for the developer and contractors. Construction under a project labor agreement; the City's detail sheet says with the AFL-CIO, and its news release names the St. Louis Building and Construction Trades Council and Missouri AFL-CIO. Enforceability depends on the recorded CBA being executed.

1. p. 1, Tax Revenue & Job Requirements. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/CBA-provisions.pdf “starting at 25 in year 1, 50 in year 2, and 100 thereafter”
2. p. 2, Equal Opportunity & Non-Discrimination. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/CBA-provisions.pdf “minority-owned and women-owned business (M/WBE) participation, workforce development, and prevailing wage compliance”
3. p. 3, Projected Jobs Detail. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/Details-on-Project-Conditions-Components-and-Benefits.pdf “Jobs: 1,050 construction jobs”
4. https://www.stlouis-mo.gov/government/departments/mayor/news/data-center-permit-approved.cfm

ShortLocal contracting falls short

A strong version: Local subcontracting goals and haul-route road repair paid by the operator

local subcontracting: yes · road repair: no

M/WBE participation, prevailing wage, and a project labor agreement. The developer must install and maintain Market Street sidewalks and a pedestrian pathway to the Grand MetroLink station. No haul-route repair term.

1. p. 3, Project Construction & Design. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/CBA-provisions.pdf “install and maintain sidewalks adjacent to Market Street and a pedestrian pathway to the Grand Metrolink station”

MetTransparency meets the bar

A strong version: No NDA, the agreement is public, and an independent audit on a schedule

NDA: no · agreement public: yes · dashboard: no · audit: annual · independent: yes

Tenants must be publicly disclosed unless commercially unreasonable due to national security. Annual reports on electricity, waste heat, and water (CBA term sheet) and on noise, PUE, waste heat, and e-waste disposal (permit conditions). The noise report is by a third party. No NDA found. The process drew criticism: an alderwoman said she was notified the morning of the virtual Board of Public Service vote, 13 appeals followed, and opponents sued in circuit court on August 28, 2026.

1. p. 3, Miscellaneous Restrictions. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/CBA-provisions.pdf “Public disclosure of tenants must be provided unless commercially unreasonable due to national security interests”
2. pp. 1 to 2. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/Conditional-Use-provisions.pdf “Maintain a Power Usage Effectiveness (PUE) of 1.25 or better (1.35 if repurposing existing building), with an annual report”
3. https://www.stlpr.org/news-briefs/2026-04-24/board-approved-st-louis-data-center-project
4. https://www.stlpr.org/news-briefs/2026-07-09/midtown-st-louis-data-center-late-july-appeal-armory

n/aTax incentives does not apply

A strong version: A but-for test before any abatement, with the forgone revenue stated

Not applicable to this deal.

abatement: 0% · PILOT: no · forgone: $0

The developer committed not to seek local tax abatement or other financial incentives for the data center or Armory buildings and to cooperate in terminating the existing Armory TIF. The City projects over $432 million ($432.3 million in its news release) in taxes and fees over ten years; STLPR reported $423 million.

1. p. 1, No Local Incentives. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/CBA-provisions.pdf “will not seek local tax abatement or other financial incentives for the data center or Armory buildings”
2. pp. 2 to 3, Projected Revenue Benefits Detail. https://www.stlouis-mo.gov/government/departments/mayor/documents/upload/Details-on-Project-Conditions-Components-and-Benefits.pdf “total projected tax revenues and fees reaching over $432 million over the first ten years”