The NSW Government's August 2026 Data Centre Guidelines fundamentally change the criteria for successful large scale data centre development. Future projects are expected not only to secure electricity, land, water and fibre, but to help create new renewable generation, energy storage and water infrastructure, minimise impacts on communities and support regional economic development. Rock Flat offers the foundations for exactly this model.
The site appears unusually well suited to development in accordance with the Guidelines. Several measures nonetheless cannot be called compliant yet, because compliance is something a designed, engineered and contracted project demonstrates, and this project is at pre-feasibility.
| Assessment | Indicative score | Interpretation |
|---|---|---|
| Strategic site fit | 85% | Very strong. Regional location, land, existing infrastructure corridors, cool climate and distance from dense residential populations. |
| Infrastructure opportunity fit | 82% | Very strong. Electricity, gas and telecommunications assets identified at or near the site; the capacity of each is not yet established. |
| Alignment with NSW policy direction | 88% | Exceptional. The Guidelines favour precisely the characteristics this precinct is assembling. |
| Current evidence and compliance readiness | 49% | Feasibility work still required. Most measures need a design, a utility agreement or an operator commitment to be demonstrated. |
| Potential compliance after feasibility | 85 to 92% | High. No measure identified that the site appears unable to satisfy. |
| Overall opportunity fit today | 82% | Compelling feasibility candidate. A screening judgement, not a compliance rating or a valuation. |
The defensible proposition. Rock Flat currently demonstrates an estimated 82% strategic fit with the NSW Government's new requirements for data centre development, with no identified policy requirement that appears inherently incompatible with the site. The remaining matters are principally engineering, utility, design and commercial matters to be resolved through feasibility.
The story is no longer whether the site could conceivably host a data centre. It is whether the site contains enough of the infrastructure and physical characteristics now explicitly preferred by the NSW Government to justify moving immediately to technical feasibility. On what has been assembled so far, the answer is yes.
The Guidelines make site selection a common theme across all six principles. Consultation feedback, they record, “identifies there are fewer complexities when data centres locate in brownfield sites with energy and water infrastructure capacity that are away from sensitive areas like homes and schools, rather than around dense urban populations.” The document also names regional NSW as a beneficiary of the investment and jobs the sector can bring, and the electricity section states that data centres outside the Sydney Ring are expected to carry smaller contribution obligations.
Two of those three characteristics are present here: infrastructure corridors on the title, and open rural land at a distance from clustered receivers. The third is not. This is greenfield grazing land rather than a retired power station or mine site, and that should be said plainly rather than argued around. What the site offers in its place is the room to build the energy infrastructure the Guidelines ask a proponent to fund, on the same title as the load.
Every figure on this page is an indicative screening judgement made at pre-feasibility by the proponent, against the published text of the Guidelines. None has been reviewed by the Department of Planning, Housing and Infrastructure, by a utility or by a data centre operator. The Guidelines describe outcomes sought by government; alignment with them is not a consent, does not alter the fact that RU1 Primary Production is not a prescribed zone for data centres, and does not substitute for the assessment pathway on the planning page.
Three ratings are used. Strong fit: the site already has a material strategic advantage. Potential fit: readily incorporated into the precinct design, but not yet evidenced. Gap: substantive investigation or agreement required. There is no rating for a fatal constraint, because none has been identified.
| Ref | NSW performance measure | Position at this site | Fit | What feasibility must establish |
|---|---|---|---|---|
| 1 | Design PUE and WUE thresholds: dPUE ≤1.25 with dWUE ≤1.0 on potable water or ≤1.6 on non-potable water, or dPUE ≤1.3 with dWUE ≤0.44 | Not a site constraint. The cool climate supports the tighter band, and the targets can be written into the operator and design brief. | Potential 90% | Cooling concept, hourly climate modelling, and a stated target dPUE and dWUE |
| 2 | Water-intensive cooling to run on 100% recycled water, or a utility agreement for the transition to rainfall-independent supply, with no adverse impact on agricultural water use | Water exists as an opportunity, but no recycled supply has been established and there is no recycled network at this location. | Potential 60% | Water source, capacity, any recycled supply, and the cooling strategy that decides whether this measure applies at all |
| 3 | Ability to reduce water use during drought restrictions while relying on potable supply | Achievable through a hybrid or closed loop design. | Potential 90% | Specify a dry, hybrid or closed loop cooling design |
| 4 | Generator emissions and air quality: Group 6 limits, or US EPA Tier 2 outside metropolitan cities and regional towns and away from sensitive receivers, subject to air quality assessment | Regional location potentially advantageous. There are dwellings in the locality, so the Tier 2 pathway must be tested rather than assumed. | Strong 80% | Sensitive receptor mapping, air quality modelling and generator technology selection |
| 5 | Quantitative noise and vibration impact assessment for construction and operation, by a qualified acoustic consultant | Regional site provides a potential separation advantage over a metropolitan one. | Strong 85% | Acoustic study and receptor mapping |
| 6 | Fire and explosion risk management for diesel, lithium-ion storage, gas and electrical works | No fundamental obstacle identified. A preliminary hazard analysis is required pre-approval for battery storage of 30 MW and above. | Potential 80% | Preliminary Hazard Analysis covering BESS, generators, gas and fuel systems |
| 7 | Forecast maximum and average water and energy demand, provided commercial-in-confidence | Cannot be completed until a campus configuration exists. | Gap 35% | Model the 50, 100, 200 and 300 MW stages |
| 8 | Smart energy and water metering to utility specification | A straightforward design requirement with no cost obstacle. | Potential 95% | Include in the design specification |
| 9 | Ability to reduce grid-supplied demand by 25% of forecast average load for up to two hours, by load shifting or on-site and proximate renewable generation and storage. Diesel cannot be used | A particularly strong opportunity: land for BESS, on-site generation and flexible load can be designed into the precinct from day one. | Strong 85% | Demonstrate the dispatch architecture and capacity; see flexibility and storage |
| 10 | Commercial arrangements with the energy utility protecting other consumers from stranded asset costs | The Guidelines expect sites outside the Sydney Ring to carry smaller contribution obligations, but grid capacity at this site is unconfirmed. | Potential 65% | Network study and commercial connection discussions with Essential Energy and Transgrid |
| 11 | Water utility agreement protecting the consumer base from infrastructure costs | Not yet established. Essential Energy's response returned no reticulated water or sewer asset in the search area. | Gap 40% | Utility engagement and a water servicing agreement, or a design that makes one unnecessary |
| 12 | Early engagement with telecommunications and optical fibre providers, including shared underground conduits | Existing fibre infrastructure identified in the area is a significant positive. Engagement is under way. | Strong 85% | Carrier confirmation, route diversity, latency and capacity; a formal carrier and fibre feasibility report |
| 13 | PPAs and firming agreements for additional NSW renewable generation: at least 40% wind by energy, storage of at least 25% of generation capacity for four hours, ten-year terms, pre-FID projects, contracted supply equal to demand from the fourth year | Highly compatible with the energy precinct concept, but no PPA exists and the obligation is not costed. | Strong potential 75% | Renewable procurement strategy and a PPA pathway, including the wind component |
| 14 | Where recycled water is unavailable, fully offset potable water use through funded supply, efficiency programs or closed loop systems | Possible using closed loop cooling or new water infrastructure. | Potential 70% | Develop a rainfall-independent water solution |
| 15 | Meaningful community and council engagement; benefit-sharing outside the development application; sovereign carriage encouraged | Regional investment, jobs and infrastructure create a strong basis for benefits. Nothing has yet been discussed with council. | Potential 80% | Formal council and community engagement strategy |
| 16 | Prioritise NSW local content and engage on local supply chains | Regional construction and the energy precinct lend themselves strongly to local procurement. Snowy Hydro's head office and workforce are about 10 km north. | Strong 85% | Local procurement and supplier strategy |
| 17 | Demonstrate support for training: apprenticeships, partnerships with providers such as TAFE NSW, bursaries tied to employment | Significant potential through TAFE, trades, energy and ICT employment. No programme designed. | Strong potential 85% | Workforce plan and training partnerships |
Measure wording is summarised from the NSW Data Centre Guidelines, August 2026, Tables 2 to 7. Fit ratings and percentages are the proponent's indicative screening judgement at pre-feasibility and carry no external endorsement. The same seventeen measures are recorded in Appendix C of the executive summary, which is the version that will carry into any application.
Regional locations, available land, existing infrastructure, additional renewable generation, large scale storage, grid flexibility, low water solutions, distance from dense residential populations, regional employment, local supply chains and high capacity telecommunications. That list is remarkably close to the premise of this campus. Six points follow, including two where the pitch has changed.
For the commercial arrangements that protect other electricity consumers, performance measure 10 states that data centres outside the Sydney Ring “are expected to have smaller contribution obligations due to greater grid capacity in many locations, reducing the need for upstream infrastructure upgrades.” That directly strengthens the regional proposition, subject to the grid study on the power page.
Measure 9 requires the ability to cut grid-supplied load by 25% for up to two hours, without diesel. A metropolitan facility may struggle to find room for a battery of the size the Guidelines’ rules would imply next to the data halls. Here it can be designed into the precinct from day one. The envelope is set out below.
Measure 13 requires at least 40% of contracted renewable energy to be wind, on ten-year terms, from projects not yet at final investment decision. The pitch therefore changes from solar plus grid to on-site solar, BESS, a NSW wind PPA, a grid connection and firming. That makes the campus a potential anchor customer for new regional generation, which is a stronger story than panels on spare land.
Gas is not a substitute for the renewable commitment. Its role is dispatchable generation, resilience, firming, emergency capability and precinct optionality. The Guidelines themselves cite overseas models where proximate gas generation or battery storage supports major data centres. The question for Jemena is now specific: at what pressure, flow rate and connection cost could the pipeline support 25, 50, 100 MW or greater generation? See Energy.
Water ranks ahead of gas in feasibility priority. Measures 2, 3 and 14 expect recycled supply for water-intensive cooling, drought resilience, and a full offset of any potable use. The concept should therefore begin with closed loop, low water or hybrid cooling as the base case, which can turn an apparent constraint into an environmental selling point. See Water.
Measure 12 requires early engagement with fibre providers. The carrier evidence gathered so far is valuable, but an operator will ask about carrier, fibre type, strands, route, distance, latency to Sydney, a physically diverse second route, cost and lead time. That becomes a formal carrier and fibre feasibility report, with two genuinely diverse paths as the target.
Two measures translate directly into a design envelope for the precinct. Both reward land, and both are easier to satisfy on this holding than on a constrained metropolitan site.
| Campus load | 25% flexible capacity | Two-hour energy equivalent |
|---|---|---|
| 50 MW | 12.5 MW | 25 MWh |
| 100 MW | 25 MW | 50 MWh |
| 200 MW | 50 MW | 100 MWh |
| 300 MW | 75 MW | 150 MWh |
The Guidelines allow this to be met through load shifting first, then on-site or proximate renewable generation and storage, with the notice period agreed with the utility. Diesel back-up generators cannot be used for this measure. On this holding, the flexible capacity can be met by a battery sized into the precinct, by shifting programmable compute and thermal loads, or by a combination.
| Data centre | Indicative minimum storage power | Indicative storage energy, four hours |
|---|---|---|
| 50 MW | 12.5 MW | 50 MWh |
| 100 MW | 25 MW | 100 MWh |
| 200 MW | 50 MW | 200 MWh |
| 300 MW | 75 MW | 300 MWh |
Very approximate, and assumes contracted generation capacity is matched to campus load. The Guidelines link storage to the contracted generation portfolio rather than to IT load, so the final figure will not be this simple. Storage can be battery or pumped hydro, part of a hybrid asset or separate, and on-site storage provided for demand flexibility under measure 9 can be counted towards this measure. No storage, generation or PPA exists; this is a design envelope for feasibility.
Why land availability matters here. A 50 to 75 MW battery installation beside the data halls, plus on-site solar, plus setbacks, plus a substation, is a footprint question before it is anything else. Up to 837.7 hectares, as supplied, is what allows all of it to be laid out without competing for space. The energy page carries the same envelope alongside the gas arithmetic.
If the whole feasibility study were reduced to the issues most likely to determine whether the project proceeds, they would be these four. Gas is an extremely useful fifth question, but the project does not necessarily fail if gas cannot be developed. It almost certainly fails as a 100 MW plus hyperscale opportunity if questions 1 or 2 cannot be answered positively.
| Priority | Gating question | Importance | Where it is addressed |
|---|---|---|---|
| 1 | Can the electricity network provide an economically viable initial 50 to 100 MW connection, expandable towards 300 MW? | Critical | Power |
| 2 | Can the site obtain two carrier-diverse, high capacity fibre connections with acceptable latency? | Critical | Connectivity |
| 3 | Can an acceptable low water or rainfall-independent cooling solution be demonstrated? | Critical | Water |
| 4 | Can sufficient land and network architecture accommodate solar, BESS and the required grid flexibility? | Critical | Energy |
| 5 | At what pressure, flow rate and connection cost could the Eastern Gas Pipeline support 25, 50, 100 MW or greater generation? | High | Energy |
Planning permissibility sits alongside these rather than among them. RU1 Primary Production is not a prescribed zone for data centres, and a pathway is required. It is treated as a gating item throughout this site because a project cannot proceed without it, but it is a question of process rather than of physical possibility, and the planning page sets out the routes available.
On 22 September 2026 the Victorian Government released its Sustainable Data Centre Action Plan. It does not apply in New South Wales. It matters here as evidence that Australian data centre policy, in the two largest states, now expects compute, new generation, water and community benefit to be designed together.
Victorian rules do not apply to a New South Wales project. Nothing in the plan binds Rock Flat, and nothing on this site should be read as a claim of compliance with it. Source: Premier of Victoria, 22 September 2026 (opens in a new tab)
The plan states that it supports the Commonwealth’s framework. Each item has a counterpart in the NSW Guidelines’ six principles and seventeen measures above.
The critical next step is a feasibility program that quantifies grid capacity, fibre diversity, water strategy and energy precinct configuration, and determines the optimal first stage of development.
The recommended next document is a data centre feasibility brief of roughly eight to twelve pages, written so that it can be sent out for quotation. It would specify exactly what each discipline has to establish, across 50, 100, 200 and 300 MW scenarios:
The NSW Government offers qualifying projects a pre-assessment service through the Department of Planning, Housing and Infrastructure, provision of environmental assessment requirements within two months, and a target of no more than 75 days in state government hands for assessment. Applicants “will need to demonstrate whether they comply with the Guidelines in their assessments.”
That is a reason to organise the feasibility work explicitly around the seventeen measures rather than as a generic property study. Every deliverable then answers a question the assessment will ask.
This is no longer a forecast. The consents for Project Pluto at Guildford West (23 July 2026) and Project Apollo at Macquarie Park (2 September 2026) require all operational electricity, IT and non-IT, to be matched at all times by firmed NSW renewable power purchase agreements before operation, with annual PUE, WUE and emissions reporting, a cap on installed generator capacity, and enclosures that can take retrofitted emission controls. Both applicants had rejected on-site storage for want of land. The pathway page sets out what twelve exhibited applications show.
Nothing here has been lodged. The 75 day target applies to assessment of a lodged application that meets the Guidelines, not to feasibility, and the Essential Energy connection process alone runs to two to three years end to end. The value of the brief is that it starts the longest clocks first.
Source: NSW Data Centre Guidelines, Infrastructure NSW, August 2026, principles 1 to 6 and performance measures 1 to 17; NSW Data Centre Policy Framework announcement, August 2026; NSW Data Centre Consultation Paper. The Guidelines state they are consistent with the Australian Government's Expectations of Data Centre and AI Infrastructure Developers, March 2026, which has not been reviewed here.
Presence and position only. No electrical capacity, gas capacity, telecommunications service, water supply or planning approval is claimed, secured or offered.
Rock Flat is seeking engagement with experienced digital infrastructure, energy and investment partners to undertake the next stage of technical and commercial feasibility. Detailed title, infrastructure, utility and commercial information is available to qualified parties.