In recent months, Amazon Data Services (ADS) Italy s.r.l. has put forward a proposal to build a data centre in Zibido San Giacomo, south of Milan. The initiative has sparked a great deal of controversy, but it is worth giving it some thought.
A total of 210 documents relating to the project have been published and uploaded to the Ministry of the Environment and Energy Security’s platform to date. The municipality of Zibido San Giacomo is situated south-west of Milan, as shown in the image below.
It is a town with a population of around 6,600, which is home to an industrial estate. Amazon chose it as the site for its data centre because there are rice paddies in the area, meaning there is a supply of water for cooling the facility.
Before continuing, it is important to clarify one point: the aim of this article is not to promote or oppose a project of this scale, but to offer a (very brief) insight into its complexity. The construction of a data centre involves not only paperwork and administrative burdens but also the views of the local community, which must be given due consideration. The reader will be able to examine statements made by local councillors and technical experts in the area. Finally, an editorial note: this article contains quotations taken from official documents submitted to the Ministry and, for this reason, we have chosen to reproduce the text of these documents faithfully.
Published documents
The more than two hundred published documents analyse various aspects of the plant’s construction: these range from geological surveys to the feasibility study, and from noise assessments to site plans of the structure. It is very interesting to examine their contents, as this reveals the analytical approach employed. One example might concern noise impact: data centres are often accused of generating significant noise pollution due to the large number of pieces of equipment they contain. Take generators or air-conditioning compressors, for instance; it is easy to assume that the noise level would have a major impact on the surrounding area. In the case of the data centre in question, a study entitled ‘SIA_All.3 – Preliminary Assessment of Noise Impact’ was carried out.
Noise impact assessment
This is a preliminary assessment, as the plant has not yet been built; however, according to the report, the study analysed the noise environment through a monitoring campaign and noise propagation models (using SoundPLAN software), evaluating three operational scenarios: daytime operation, night-time operation and emergency situations. SoundPLAN, as stated in the report, is
an internationally recognised and widely used noise propagation model for estimating the sound pressure levels reached in specific areas. The software applies the method known as ‘ray tracing’. Sources are modelled as surfaces, lines or points; acoustic waves propagate from each source. The resulting acoustic field depends on the absorption and reflection characteristics of all obstacles present between the source and the receiver. In the area of interest, the acoustic field is the sum of the sound energy from the ‘n’ rays reaching the receiver. The propagation of noise from industrial sources (point, line and area sources) is calculated by applying the technical standard ISO 9613 Acoustics – Sound Attenuation During Propagation in the Outdoor Environment – Part 2: General Calculation Method.
Based on the analyses carried out regarding daytime and night-time operation, the simulations indicate that the data centre, when operating on electricity from the grid, does not exceed the absolute or differential noise limits laid down by the regulations.
The image above (on page 21 of the document) shows noise pollution measured in relation to geographical distance. The report concludes that:
As can be seen, there are no instances where the differential or absolute limits have been exceeded. It is important to note that the differential parameter was not calculated at the perimeter, as this is not required by the regulations given that there are no residential settlements or areas suitable for habitation; the values at the perimeter were calculated solely to ensure that the noise produced did not, in absolute terms, contribute to an increase in the perceived noise levels in the neighbouring industrial or agricultural areas.
In the emergency scenario, there are slight, widespread exceedances during the night. However, this scenario is considered highly sporadic (linked to prolonged power cuts) and does not constitute the standard operating condition. The report clarifies important aspects regarding this scenario.
This is an emergency scenario and does not represent standard operating procedure, but rather a backup response in the event of a prolonged power cut. All systems within the data centre building will therefore be active, including all systems dedicated to cooling (roof-mounted units) and temperature control (louvers). All generators and the load bank, located on the northern perimeter as in the Daytime Operation scenario, are expected to be operating simultaneously. This scenario could potentially occur at either day or night, although it is a very rare and unpredictable event.
It should also be noted that, in accordance with the ministerial guidelines, this condition is not subject to compliance with regulatory limits. The findings set out in the report show the following.
It may be useful to compare these figures with a standard decibel chart.
Geological Impact Assessment
There is a “Geological Report” dated 31 October 2025 (reference Z-G-PDC-REL-XX-03) which essentially shows that the entire area was previously used for gas extraction and is situated on flat terrain characterised by Quaternary fluvioglacial deposits. In simple terms, this consists of alternating layers of sand, gravel and silt. The average geological profile shows surface fill material, followed by thick layers of gravelly sand interspersed with thin layers of clayey silt down to a depth of 50 metres. Ground-penetrating radar surveys were carried out, which ruled out the presence of any hidden old foundations; only a few utility ducts and pipes (water or gas) were identified, none of which directly interfere with the building’s construction area.
Water, seismic risk and environmental constraints
However, the report also points to something else, something important: the presence of water. The aquifer is very shallow, lying between 1 and 2.5 metres below ground level. The groundwater flow moves from north-west to south-east. During the works, it is conservatively estimated that the water may reach 1 metre from the ground or even ground level at certain times. The report states:
The municipality is classified as Seismic Zone 3 (low seismicity). Technical analyses indicate that the soil falls within ‘Category C’. No risk of soil liquefaction (a phenomenon in which the soil loses its strength during an earthquake) has been identified. To ensure greater safety, AWS has specified design parameters that exceed the minimum legal standards. According to the PGRA classification, the site is not prone to flooding.
The municipality is classified as Seismic Zone 3 (low seismicity). Technical analyses indicate that the soil falls within ‘Category C’. No risk of soil liquefaction (a phenomenon in which the soil loses its strength during an earthquake) has been identified. To ensure greater safety, AWS has required design parameters that exceed the minimum legal standards. Seismic analysis is essential to prevent destructive events that could potentially disrupt service continuity.
Most of the area is available for development, subject to minor restrictions. However, a 10-metre strip along the ‘Cavo Basiglio’ canal is protected: building is prohibited in that area so as not to compromise hydraulic safety.
Data centre waste management
In the case of Zibido San Giacomo, the document “SIA_All.2 – Environmental and Territorial Reference Framework” also analyses waste management. In 2022, the municipality recorded a medium-to-high level of waste generation, ranging between 425 and 550 kg per inhabitant per year (page 99); total municipal waste generation stood at approximately 2,936 tonnes, of which 76.6 per cent was collected separately. The data centre will, of course, have to manage its waste in accordance with the procedures laid down by law, but it is reasonable to ask what types of waste are produced by a facility of this kind.
- Municipal solid waste: generated by office areas, toilet facilities and catering areas.
- Non-hazardous special waste: arising from packaging, routine maintenance, the replacement of air filters (air handling units) and water treatment systems.
- Hazardous special waste: generated mainly during the maintenance of technical equipment and requiring particular attention with regard to recycling and reuse (such as batteries) and chemical elements such as antimony and lead.
- WEEE (electronic waste): this includes end-of-life servers and IT equipment. Specific management plans must be drawn up for these in accordance with the 2024 MASE and Lombardy Region Guidelines.
- Construction waste: waste generated during the construction phase, including materials resulting from ground levelling and excavated soil and rock.
Light pollution
Another interesting point raised in the document mentioned above relates to light pollution. The document states:
From the perspective of environmental studies, the issue of light pollution is particularly significant for a number of reasons. In terms of its impact on biodiversity, excessive night-time lighting can disrupt natural ecosystems, affecting the predation, reproduction and migration behaviours of nocturnal animals. Certain species of birds, insects and mammals may be particularly sensitive to artificial light, which can disrupt their biological cycles.
It also has an impact on energy consumption; indeed, light pollution leads to the inefficient use of energy resources. Many lights are designed to be directional but often emit light upwards or to the sides, wasting energy and increasing lighting costs without any tangible benefits.
It also has an impact on human health, as excessive exposure to light at night can disrupt people’s natural circadian rhythms, affecting sleep and quality of life. This can lead to health problems such as sleep disorders, stress and metabolic disorders. There are also psychological and social impacts; indeed, excessive lighting can negatively affect people’s psychological wellbeing, creating uncomfortable urban environments and affecting the perceived safety in cities.
To this end, a measurement method known as SQM (Sky Quality Meter) was used, which works as follows: the higher the value returned by the instrument, the better the visibility of the night sky. According to the measurement carried out, the value returned was 18.97 mag./arcsec².
The report shows that this figure is in line with typical values for metropolitan areas in the Milan region, but it should be borne in mind that an uninhabited area with no artificial light has a value of precisely 22 mag./arcsec².
Main issues identified
It is indeed very interesting to examine the aspects analysed and taken into account in projects of this scale, and their implications. A project of this scale can give rise to a number of problems of various kinds, and below we have attempted to summarise the most significant aspects.
From the point of view of sustainability and local impact
- Lack of analysis of cumulative impacts: there is no comprehensive assessment that takes into account the combined effect of the project and other nearby developments, such as the APTO Data Centre in Lacchiarella.
- Land take: the project would result in the sealing of valuable agricultural land, contrary to the guidelines which prioritise the regeneration of brownfield sites. In this regard, the MASE (Ministry of the Environment and Energy Security) states:“Furthermore, it should also be noted that the area, as stated by the Proponent itself, is not conducive to the dispersion of pollutants and that the implementation of the project would result in the consumption of green space in an area that is already heavily sealed, which is inconsistent with the objectives of reducing land consumption, as also set out in Lombardy Regional Law No. 31 of 28 November 2014, and with ministerial and regional guidelines, which prioritise development on brownfield sites.”
- Geological feasibility: part of the site falls within a feasibility class (Class 4a) which imposes severe restrictions and prohibits new construction.
Road Conditions and Traffic
- Underestimation of trafficflows: the traffic analysis is considered inadequate; there is a lack of realistic data on heavy goods vehicles during the construction phases.
- Inadequate road infrastructure: the local road network does not appear capable of withstanding the anticipated loads, posing a risk of traffic passing through residential areas and affecting public safety. This was stated, in particular, by local councillors Pietro Cataldi and Patrizia Bergami, members of the Bene Comune – Zibido San Giacomo council group. The councillors point out that the documentation submitted is deficient in terms of the assessment of cumulative impacts and genuine territorial sustainability, potentially contravening the principles enshrined in current legislation. The councillors have submitted comments addressed to MASE (OFFICIAL REF. NO. ENTRY 0074215.06-04-2026) in which they set out these observations.
Water Resource Management
- Indiscriminate use of water: there is a lack of information regarding the construction of new wells and their overall impact. This was highlighted by Mr Ambrogio Noé, who wrote to MASE regarding“gaps in information that prevent an adequate assessment of the critical issues surrounding the indiscriminate use of WATER”(MASE. OFFICIAL REGISTER.ENTRY.0072390.02-04-2026).
- Hydraulic risk: concerns have been raised regarding the management of drainage and the risk of flooding – a long-standing problem in the area – as well as the overheating of water injected into the aquifer. Engineer Noé also writes:“In this regard, it should be noted that the problem of flooding and high water levels affects the lower Milanese plain, but does not affect the Rho Pero area, where other similar wells are being requested at the same time, but in an area less prone to flooding and high water levels […] By how many degrees Celsius is the external environment adjacent to the Data Centre and the surrounding air – and therefore the environment of the rice paddies – expected to heat up, given that the water will be used to cool the plant? And given that, for some years now, the summer months in the area have been characterised by extremely high temperatures and dry conditions, regardless of the additional issues introduced by the data centre.”
Conflicts with Private Ownership and Transparency
- Planning on other people’s land: several landowners have complained that the power line route crosses their agricultural land without prior agreement or notification. Mr Noé has written a document to MASE (MASE.OFFICIAL REGISTER.ENTRATA.0071228.01-04-2026) stating: “A power line that appears to be planned – or rather, conceived – to run through the rice paddies of the undersigned and other farmers, who were completely unaware of this until a few days ago! Farmers who were, however, contacted in March by an Amazon representative who already wanted to organise excavation work in the rice fields for the power line! As if it were a power line and a route that had already been decided upon and was to be implemented immediately!”
- Damage to agriculture: the construction of the power line would make it impossible to grow rice using the flooded-field method, as heavy agricultural machinery would sink into the ground and the line would interfere with irrigation systems.
Additional Information Requested by the Authorities
- Incomplete documentation: the Technical Commission has requested further details regarding planning and hydraulic aspects, as well as consistency with the Regional Spatial Plan. (MASE.OFFICIAL REGISTER.RECEIPT.0088893.27-04-2026)
- Impact on the landscape: the Ministry of Culture has requested a more detailed assessment of the visibility of the plant from key vantage points (such as the towpath of the Naviglio Pavese) and the effects of emissions from the emergency generators.
Finally, there is one aspect to which the reader’s attention is drawn: the local community’s involvement in projects of this scale is by no means to be underestimated. Many of the authors have nothing against these projects but call for transparency and objectivity in the assessments. Mr Noé himself, who has been cited on several occasions in connection with the documentation sent to MASE and published on the ministry’s own platform, clearly states:
Furthermore, I am wholeheartedly in favour of the construction of the data centre, as it brings prosperity and progress, but on the essential condition that the project is developed and managed in an extremely responsible and professional manner, with due regard for the surrounding environment, and therefore does not damage the environment of the adjacent rice fields.
These are objectively justifiable and reasonable requests which raise important issues for consideration in the management of projects that do not concern only the municipality of Zibido S. Giacomo.
Conclusions
Projects such as the one in Zibido San Giacomo highlight the need for the coordination of such works to be as transparent and objective as possible. Public authorities today are called upon to respond to a demand for infrastructure and technological development that is significant but also potentially problematic. What could be done in this regard? Certainly, a common and consistent model for the development and management of these projects could be devised; perhaps under the supervision of agencies such as AgID, which, as it states, is:
The technical agency of the Prime Minister’s Office responsible for ensuring the achievement of the objectives of the Italian Digital Agenda by coordinating all the country’s public administrations. It also contributes to the dissemination of information and communication technologies, promoting innovation and economic growth. Finally, it promotes digital skills and their uptake, working in partnership with institutions and international, national and local bodies.
It is important to make it clear that the issues identified in the municipality of Zibido San Giacomo are common to those faced by many other local authorities involved in similar initiatives and, as such, must be dealt with in a serious and transparent manner.
