Global Risk

Tracking Hyperscale AI Data Center Growth with Satellite Imagery

05.12.26 | 32 min read | Text by Christina Krawec

The advancement of AI is inextricably linked to its physical foundations. Hyperscale data centers power the world’s most advanced AI models, and the demand for these facilities continues to accelerate. Governments and frontier AI developers alike are investing tens to hundreds of billions of dollars into hyperscale data center buildouts, sparking debates on the economic, environmental, and geostrategic impacts of such efforts. On the international stage, AI is increasingly considered a source of economic growth and an asset to military capabilities, resulting in global competition, particularly between the U.S. and China. In addition, the successful operation of data center facilities requires high quantities of energy, affecting local communities and the environment. Therefore, from grassroots community impacts to global geopolitical dynamics, understanding developing data center capacities is emerging as a critical analytical challenge.

The speed at which AI models are advancing necessitates the rapid growth of its supporting data center infrastructure. In tracking data center construction and operation, what can remote sensing—particularly, the use of electro-optical (EO) satellite imagery—meaningfully illustrate about data center development, and what can policymakers learn from this data moving forward? While multiple research organizations have utilized satellite imagery to track construction and ongoing activity at hyperscale data center facilities, no baseline assessment of its benefits and limitations is available in the public sphere. This research addresses that gap with two case studies: Khazna’s Ajman data center facility in the United Arab Emirates (UAE) and xAI’s Colossus data center site in Memphis, Tennessee. These examples reveal inconsistencies between commercial announcements and on-the-ground activity visible in satellite imagery, showing that official construction timelines, infrastructure permits, and company publications cannot be relied upon exclusively for insights into data center development. Satellite imagery provides a layer of independent verification that can be integrated to overall assessments of data centers, and this study illuminates where this imagery adds insight to inform future AI policy efforts. In particular, as discussions of international AI governance evolve, satellite imagery can be integrated as one verification method in a wider toolkit supporting the monitoring and implementation of future AI-focused agreements. 

Acknowledgements

This work draws on Epoch AI’s Frontier Data Centers Hub project—an effort to which the author contributed as a Supervised Program for Alignment Research (SPAR) Fellow—and builds on information originally collected by other members of the project that was further expanded upon for the research. This report was written for and funded by the 2025 GovAI Fall Fellowship. 

This report was edited for publication by the Federation of American Scientists, and the author would like to thank Matt Korda and Dr. Oliver Stephenson for their contributions and support in bringing this publication to completion.

Introduction

Data centers are an integral part of the AI ecosystem and impact finance, the environment, and international strategy. The total expected financial investment into data centers spans billions of dollars—and is expected to hit the trillions. The scale of these facilities is also massive: in July 2025, Meta CEO Mark Zuckerberg announced plans for the construction of the Hyperion data center, expected to have a one-gigawatt capacity and cover a land space almost the size of Manhattan. Thus, data centers have significant economic and industrial ramifications as they continue to be developed. The sheer size and scale of these facilities requires high amounts of energy, with these needs driving environmental concerns regarding the overall impact of AI. The Electric Power Research Institute in particular forecasts that data centers will use 9-17% of total U.S. electricity by 2030 (an increase from 4-5% today). In addition, on the international stage, high levels of AI technology have increasingly been seen as a marker for technological supremacy, with countries prioritizing not only the development of AI models themselves but their integration into military systems as national priorities. All of these elements have caused a degree of public backlash regarding data center construction across the globe, reflecting local concerns about energy needs and fears surrounding the unregulated advancement of AI having significant geopolitical destabilizing effects. 

Despite this extensive media, political, and analytical attention, public information on data center facilities is often incomplete or opaque, generating uncertainties about their pace of development. In this context, satellite imagery is one tool for monitoring the development and operation of these sites as a form of independent verification.  This report thus examines the role satellite imagery can play in tracking data center infrastructure development and operation using electro-optical (EO) imagery and two case studies: Khazna’s Ajman data center in the UAE and xAI’s Colossus data center in Memphis, Tennessee

The following sections outline an analytical framework, assess observable indicators in satellite imagery, and apply them to these two case studies. The work compares visible features on imagery to commercially announced milestones, informing future forecasting efforts on data center buildout timelines and identifying areas where satellite-derived insights are limited or indeterminate. Recommendations for next steps are included in the conclusion of the report, and outline the role satellite imagery of data centers can play in commercial, government, and local communities. At the international level, discussions of potential multilateral AI governance frameworks are ongoing; satellite imagery is particularly suited to serve as one complementary layer to independently verify commitments under future AI-related agreements.

Comments on Existing Literature

Data center locations are not available in one comprehensive, publicly-available database. Instead, corporations themselves may choose to disclose the locations of their data centers through announcements or publications (i.e. Google’s Data Center directory). Other aggregators such as Data Center Map, Baxtel, and Pacific Northwest National Laboratory’s Open Source Data Center Atlas independently use permits, news articles, and other open source information to collect information and display data center locations. However, the completeness and accuracy of these listings vary. Thus, satellite imagery is one additional layer of independent information that can provide credibility to existing geographical information on data center facilities.

Several organizations have expressed interest in utilizing satellite imagery to track data center construction and operation. Notably, Epoch AI’s Frontier Data Centers Hub uses satellite imagery, permit data, and other open sources to track hyperscale data center buildout within the U.S.. In addition, Semianalysis has a data center analytical model that also relies on satellite imagery to provide commercial and industrial insights on data center activity for private companies. However, the Semianalysis model is not publicly available and is instead sold to companies for forecasting, business intelligence, energy usage, construction tracking, and environmental assessment purposes. Epoch AI’s methodology is publicly available, but does not detail how specifically to analyze the imagery itself, focusing on broader applications for energy usage calculations.

Therefore, while there is a clear interest in this type of analysis, there is still ample space to expand upon the impacts satellite imagery analysis can have in the AI field. This research provides a broad overview of satellite imagery’s capabilities for hyperscale data center tracking, providing an assessment of its benefits and limitations.

Satellite imagery has also long been integrated into media reports as a flashy and attractive visual for news articles, and data center construction is no exception. In October 2025, Business Insider published a high-level article illustrating the growth of U.S.-based data centers on satellite imagery. This displays an appetite in the public sphere for visual representations of data center expansion. Articles such as these lack the detail of traditional imagery analysis, and could benefit from additional context that formal analyses can provide. More generally, satellite imagery data is useful for a variety of stakeholders: governments can use satellite imagery of data centers to inform policy decisions regarding AI-related infrastructure expansion in the face of perceived international competition and strain on electricity grids. Frontier AI labs can integrate imagery assessments to stay informed of the progress of their (and their competitors’) data center development. In addition, the public can harness satellite imagery to increase transparency of local development projects and ensure that companies are adhering to their permit terms and legal obligations. This research in particular addresses the latter, displaying how satellite imagery adds transparency for verification of corporate data center operational activities.

Among researchers, some skepticism remains about the use of satellite imagery to track data center construction. In late 2024, Lennart Heim and Konstantin Pilz argued that satellite imagery of data centers can be limited in its usefulness to track the proliferation of computing power. Their assessment took a conservative view of satellite imagery’s utility, stating that elements such as chip quantity, chip type, and power consumption levels are difficult to extract. While it is true that EO imagery cannot directly observe GPUs or other indoor hardware, this research argues that satellite imagery is valuable for independent verification of visible infrastructure and construction progress, and for making broad data center capacity estimates.

Opportunities and Challenges of Utilizing Satellite Imagery for Data Center Monitoring

Electro-Optical Imagery Basics & Uses

Overview of Electro-Optical (EO) Imagery

Electro-Optical (EO) imagery is satellite imagery that is collected via sensors that detect sunlight signatures in the visible and near-infrared portions of the electromagnetic spectrum. Therefore, depending on the collection parameters and post-processing, finished and published EO imagery products will generally look like a “photograph” from above to the naked eye. EO imagery is widely available commercially, both free of charge and for purchase. Commercial providers such as Airbus, Planet Labs, and Vantor are commonly-used sources of paid satellite imagery, with prices ranging from roughly $15 to several hundreds of dollars per square kilometer, depending on the area of interest, resolution, and provider. Free sources of satellite imagery can be acquired via platforms such as Google Earth Pro, European Space Agency’s Copernicus Sentinel program, and NASA Earthdata/Landsat. This is generally archival imagery or lower-resolution than resources available through paid providers. For more information on satellite imagery analysis basics, see FAS’s prior publication on the topic, A Guide to Satellite Imagery in the Nuclear Age: Assessing China’s CFR-600 Reactor Facility

The spatial resolution of an image determines its level of granularity and detail. A high-resolution image is considered anything better than one-meter resolution: in other words, the length of each pixel represents one meter.At ten-centimeter resolution, therefore, one pixel represents ten centimeters on a side, corresponding to a 10-centimeter by 10-centimeter ground footprint.

Fig. 1. Comparison of satellite image resolutions at different ground sampling distances. Source: Wikimedia Commons, CC0 Public Domain.

At a typical industrial facility—for example, a nuclear reactor, water treatment plant, or coal processing facility—the following features can be identified in high-resolution satellite imagery: 

Fig. 2. Example of satellite imagery used to identify features at China’s CFR-600 nuclear reactor facility. Source: A Guide to Satellite Imagery in the Nuclear Age: Assessing China’’s CFR-600 Reactor Facility, Federation of American Scientists, December 2025

Figure 2 shows an example of EO satellite imagery being used to identify infrastructure at a nuclear reactor. Some of these principles can also be applied to monitoring data center development and construction, as discussed in the following sections.

Data Center Applications

Feature Identification

EO imagery can be used to identify specific infrastructural features of interest at a data center facility. The following generalities have been drawn from U.S.-based hyperscale data centers operated by frontier AI developers, and these features can be identified on imagery of at least 50-centimeter resolution. Some features from international facilities have also been included.

While the features outlined below display several visual patterns to make identification on satellite imagery feasible, it is vital to note that these features and their arrangements are highly variable, and the patterns outlined in this section are guidelines rather than strict rules. This is discussed further in the Limitations section below.

Appendix A contains a summary of the key features of a data center, the satellite resolution necessary to resolve them, their distinguishing elements, and potential obstacles. 

Main Data Halls

The main building of a hyperscale data center facility houses the equipment used for AI applications, including racks, servers, and chips. These are generally sizable buildings that have a large geographic footprint. On satellite imagery, they appear as the “main” and largest building in an area. The main buildings may have white or pale-colored rooftops for reflectivity and temperature control as well. They also commonly have flat or low-sloped rooftops for ease of installation of HVAC equipment on top.

Fig. 3. Main data hall, du Data Center Silicon Oasis, Dubai, UAE, July 22, 2025. Coordinates: 25°7’58.32″N, 55°23’30.16″E. Image: Google © 2025 Airbus

Fig. 4. Meta Prometheus, New Albany, Ohio, U.S.A, July 2, 2025. Coordinates: 40°4’6.24″N, 82°45’1.34″W. Image: Google © 2025 Airbus

Fig. 5. Alibaba Zhangbei Data Center, Zhangjiakou, China, November 7, 2024. Coordinates: 41°11’34.73″N, 114°41’53.37″E. Image: Google © 2025 Airbus

Data center halls are identifiable both by their size and their surrounding infrastructure (discussed in the following sections). Note that, for a data center site, if a building takes up a similar large footprint but only trucks or loading areas are visible around its edges, it is likely a warehouse instead and not an IT-specific building.

Support/Administrative Buildings

Administration buildings will generally be built closer to an entrance or parking area at a data center site. They will have a much smaller footprint than the main data hall but will be located in its general vicinity.

On-site Grid Power

Substations and switchyards manage grid power for distribution to the rest of the data center facility. Substations—used for voltage transformation and power distribution—are generally distinguishable by the presence of power transformers (see Figure 6). Switchyards, on the other hand, reroute power without changing the voltage, and will generally not have transformers visible. In the U.S., they are generally identifiable by their appearance as open, flat, gray concrete lots with rod- or pipe-like features, thin metal infrastructure, and adjacent blocks. Expected features include steel gantries (frames providing stable support for other equipment), transformers (boxes used for electrical transfer), and busbars (metallic strips used for conduction and energy transfer). Thick cables or rod-like features might be visible connecting a substation to the main data hall, but this is not always necessarily the case, as both overground and underground feed systems could be in use. In addition, in higher-resolution imagery, power lines and their associated towers connecting to the substations could be visible.

Fig. 6. Granite Point Data Center Campus Substation, Bluffdale, Utah, U.S.A, June 1, 2025. Coordinates: 40°28’45.18″N, 111°54’26.34″W. Image: Google © 2025 Airbus

In some locations, the on-site grid power will be housed within a dedicated building. Indoor substations could indicate that they are gas-insulated switchgear (GIS) substations, medium-voltage (MV) distribution substations with air-cooling systems, indoor transformer halls (housed inside for noise reduction), or a combination of these.This is particularly true for hot and dry countries such as the UAE; substations in these environments could be located indoors for temperature control purposes. Therefore, substations and switchyards will not necessarily look the same at data centers around the world.

Main and Backup Power Generation 

Data centers require significant amounts of energy to operate, typically ranging from tens to hundreds of megawatts (MW), with gigawatt (GW)-scale facilities now emerging. The high environmental cost of data center operation has placed them in the spotlight: from grassroots organizations to the United Nations, global communities have raised myriad concerns regarding the strain data center facilities place on electricity systems and water resources.

For hyperscale data center facilities, power generation infrastructure ensures that the main buildings have consistent access to adequate power. Main power generators come in various designs, but are often natural gas turbines (see Figure 7). They will appear larger than backup generators, and will have cylindrical exhaust stacks which appear circular on imagery. However, not all data center facilities will show a main power generation source. In some cases, the power plants supplying energy are offsite and not necessarily visible at the facility itself.

Fig. 7. Screen capture of OpenAI Stargate Abilene facility main power infrastructure outlined in pink within the Epoch AI Satellite Explorer, image dated September 26, 2025. Coordinates: 32°30’16.17″N, 99°46’31.20″W. Image: Epoch AI Satellite Explorer © 2025 Airbus via Apollo Mapping

Backup generators—often diesel—provide emergency power to the main hall if the main power fails. These generators will usually be numerous and in close proximity to the main data hall. They will appear as smaller, thinner rectangles arranged in rows. They will not have fan features (and therefore can be distinguished from cooling infrastructure). Their regular spacing and alignment along the main building perimeters are distinctive. See Figure 8 for an example.

Fig. 8. Screen capture of Amazon Madison Mega Site facility backup power outlined in purple within the Epoch AI Satellite Explorer, image dated October 4, 2025. Coordinates: 32°35’46.34″N, 90°5’40.50″W. Image: Epoch AI Satellite Explorer © 2025 Airbus via Apollo Mapping

Cooling Infrastructure: Chillers and Cooling Towers

Cooling infrastructure is vital for removing heat from data halls. Chillersactively remove heat from the data center cooling loop. Cooling towers are heat-rejection systems used to release heat to the atmosphere. Chillers and coolers will generally be colocated at a data center site; however, not all data centers require both. For example, water-cooled systems typically require cooling towers to release heat, while air-cooled systems do not, instead blowing air at a refrigerant-filled coil for heat dissipation. Cooling towers are distinguishable by their arrangement in rectangular or square clusters with large circular fan openings (see Figure 9). These fans are distinct on high-resolution imagery, spanning several feet in diameter.

Fig. 9. Examples of cooling towers. Left: Red Oak Google Data Center, Red Oak, Texas, U.S.A, August 24, 2025. Coordinates: 32°32’22.49″N, 96°47’31.47″W. Image: Google © 2025 Airbus
Middle: AirTrunk Iskandar Puteri, Iskandar Puteri, Malaysia, April 29, 2025. Coordinates: 1°26’6.45″N, 103°36’3.43″E. Image: Google © 2025 Airbus
Right: Switch Citadel Campus, Sparks, Nevada, U.S.A, June 19, 2025. Coordinates: 39°32’19.60″N, 119°26’12.77″W. Images © Airbus via Google Earth Pro. Image: Google © 2025 Airbus

Chillers, on the other hand, will usually be boxy or container-like in shape (See Fig. 10). Air-cooled chillers could show smaller circular fans arranged in a grid, but these are smaller in size and generally only distinct in ultra high-resolution imagery (higher than 30-centimeter resolution; see Table  A for further details). Water-cooled chillers are generally housed indoors, and therefore would not be visible in EO imagery, but this is not universally the case at every facility.

Fig. 10: Examples of chillers. Left: Digital Realty ORD10 / Lakeside Technology Center, Chicago, Illinois, U.S.A, August 7, 2025. Coordinates: 41°51’14.35″N, 87°37’5.70″W. Image: Google © 2025 Airbus
Middle: Equinix LD5, Slough, United Kingdom, August 16, 2025. Coordinates: 51°31’2.18″N, 0°37’0.74″W. Image: Google © 2025 Airbus
Right: QTS Microsoft Fayetteville Data Center, Fayetteville, Georgia, U.S.A, October 31, 2025. Coordinates: 33°27’7.89″N, 84°31’18.58″W. Image: Google © 2025 Airbus

Construction and Change Over Time

Crucially, EO imagery can be used to track the construction of a data center over time. Using several satellite images of a data center collected over the course of months or years, the footprint of land use can be monitored chronologically. EO imagery is well-suited for tracking change over time, as progress is often significant enough to be seen on medium- to high-resolution imagery available publicly. Construction milestones are particularly useful for assessing future buildout: understanding the time required to build a data center can assist in planning for energy needs and estimating energy capacities. Case Study 1, the Ajman Data Center in the United Arab Emirates, is an example of satellite imagery used to track chronological data center expansion.

Case Study 2. Feature Identification at xAI’s Colossus Data Center Facility

Background & Context

Epoch AI’s Frontier Data Centers Hub, released November 2025, analyzes over a dozen hyperscale data center facilities to track energy usage, construction timelines, and compute. One feature, the Satellite Explorer, provides high-resolution EO imagery annotations of critical infrastructure and tracks change over time. The author of this report contributed to the satellite imagery analysis and annotations for the Satellite Explorer, and this study selects one of the Hub’s data center facilities—xAI’s Colossus installation in Memphis, Tennessee—and discusses methods for feature identification, outlining how this methodology can be applied to other large-scale data center sites as well.

xAI’s Colossus supercomputer is run by a hyperscale data center facility in Memphis, Tennessee. The facility boasts a capacity of 200,000 GPUs and is one of the largest operational AI training clusters worldwide. At this size and scale, this installation is ideal for identification of expected features at completed hyperscale data centers. While this example on Epoch AI’s hub can also be used for tracking construction and buildout (similarly to Ajman), because the facility is operational, it is used in this report specifically for feature identification purposes.

Feature Identification

Fig. 21. Screen capture of xAI Colossus Data Center facility annotations within the Epoch AI Satellite Explorer, image dated October 19, 2025. Coordinates: 35°3’35.09″N, 90°9’22.33″W. Image © Airbus via Apollo Mapping.

Main Building

The main building at this facility is determined by its central location in the image, flat white reflective rooftop, and large footprint in comparison to the surrounding infrastructure. While this type of main data hall might not be immediately identifiable on its own, its proximity to the other infrastructure and its size indicates its status as the main building.

On-site Grid Power

Three substations are visible at this facility, outlined in Figure 21 in orange. Each of these three shows the expected visual signatures: they are rectangular, gray concrete lots with thin steel structures (that may throw stark, visible shadows across the lot if the sun is not directly overhead). These are the gantries, transformer blocks, and busbars. This identification is further validated by open sources (Figure 22): the Memphis Light Gas and Water (MLGW) publicly reported the location of two of the substations by using Google Earth satellite imagery and making its own annotations, outlining the substation locations.

Fig. 22. Memphis Light Gas and Water (MLGW) imagery annotation and confirmation of xAI Colossus substation locations, July 9, 2024. Image date: April 17, 2023. Coordinates: 35°3’35.09″N, 90°9’22.33″W. Image: Google © 2025 Airbus

While it has its limitations, satellite imagery can be used for estimating power generation and capacity in some instances: for example, in July 2024, MLGW annotated Google Earth satellite imagery (Figure 22), revealing that the substation to the northeast of the facility had an 8 MW capacity and that the “future” substation located to the northwest would have 150 MW capacity. In Figure 21, a third substation located to the southeast is roughly the same size as the northwest substation. Therefore, it can be inferred that the third substation can also provide approximately 150 MW.

In May 2025, MLGW further announced that “xAI is receiving 150 MW of power at the Paul Lowry site. xAI requested an additional 150 MW at this location, for a total of 300 MW. A substation is being built to accommodate this request … MLGW anticipates that xAI will receive an additional 150 MW in Fall of 2025.” The announcement notes that 8 MW are being drawn from an “adjacent, pre-existing MLGW substation” (to the northeast) and 142 MW are being generated from the “newly constructed” substation (to the northwest). Therefore, the initial conclusion that the third southeastern substation has a capacity of approximately 150 MW was broadly accurate.

In this situation, EO imagery allows for the identification of the third substation and assists in energy estimations. However, it is only marginally accurate, since the northwestern substation is providing 142 MW and the southeastern substation will provide 150 MW. Therefore, exact estimations may not be feasible using satellite imagery.

On-site Main and Backup Power

Fig. 23. Close-up of main and backup power infrastructure annotations within the Epoch AI Satellite Explorer, image dated October 19, 2025. Coordinates: 35°3’26.33″N, 90°9’22.48″W. Image © Airbus via Apollo Mapping.

Fig. 24. Close-up of main and backup power infrastructure annotations within the Epoch AI Satellite Explorer, image dated October 19, 2025. Coordinates: 35°3’43.66″N, 90°9’21.15″W. Image © Airbus via Apollo Mapping.

Main (or on-site) power generators and backup generators will have differing visual indicators, as seen on Figures 23 and 24. For the Colossus facility, the main power generators are natural gas turbines. These types of turbines are distinguishable by the appearance of cylindrical exhaust stacks. In addition, just north of the exhaust stacks, square gray structures show the turbine air inlet filters. The turbines are also characterized by mushroom-cap-shaped features, visible north of the air inlet filters with appearances as white-blue horizontal structures with curved shadows to the north. These main power generators will also generally be grouped together and arranged in neat rows all facing the same direction.

Fig. 25. Gas turbine and backup power units visible in aerial imagery taken from the northeast looking southwest, image dated March 31, 2025. Image © Steve Jones Flight by Southwings for SELC.

In contrast, backup generators (outlined in purple in Figures 23 and 24) will show different visual indicators. They are smaller in size than the main power turbines, often rectangular in size and arranged in neat rows. They appear as pale-colored, container-like structures, and have no strong visual indicators. Long, rectangular white boxes in satellite imagery suggest the presence of backup generators such as these. 

Identification of these gas turbines, over the course of 2025, was of particular use and interest to the Memphis local community. In 2024, xAI was offered permits for installing 15 temporary natural gas turbines at the site. However, by April 2025, 35 turbines were visible at the site, captured in aerial imagery. (Note that this was not satellite imagery, but imagery taken with an overhead airplane. This flyover was commissioned specifically for this purpose. However, satellite imagery can still be used to detect the quantity of turbines at the site.) These 35 turbines were in clear violation of the permitting rights that had been allotted to xAI. Following public complaints, xAI began dismantling the extra turbines. By July 2025, xAI was approved to have 15 permanent gas turbines on site. In Figure 21, dated October 19, 2025, 12 turbines are visible, implying that xAI is adhering to the legal allowance. This instance reveals how imagery can be utilized for ensuring that companies are complying with their legal commitments. 

Cooling Infrastructure

Epoch AI’s recent work focuses particularly on using cooling infrastructure to make estimations on total cooling capacity and power consumption. This methodology has been demonstrated in the Frontier Data Centers Hub, which integrates satellite imagery, permitting documents, and company disclosures to model power, compute, and cost metrics across AI data centers.

Before calculations on energy output can be made, the cooling infrastructure must be identified and counted. Figure 21 shows the xAI Colossus cooling infrastructure outlined in blue. Close-ups are provided below in Figures 26 and 27.

Fig. 26. Close-up of cooling tower infrastructure annotations within the Epoch AI Satellite Explorer, image dated October 19, 2025. Coordinates: 35°3’32.30″N, 90°9’18.87″W. Image © Airbus via Apollo Mapping.

Fig. 27. Close-up of air-cooled chiller infrastructure annotations within the Epoch AI Satellite Explorer, image dated October 19, 2025. Coordinates: 35°3’26.41″N, 90°9’29.79″W. Image © Airbus via Apollo Mapping.

The Colossus data center facility is unique in that both cooling towers and air-cooled chillers are used. The cooling towers are more easily identifiable as large rectangular blocks with multiple circular fan features on top arranged in a row. The air-cooled chillers are often smaller in size than the cooling towers. They are also arranged in neat rows and also have many small fans on top (as opposed to the cooling towers, which show several much larger fans). 

Counting the blocks of chillers and the cooling towers can then be used, as per the Epoch AI calculations, as inputs for quantitative power-capacity estimates. Epoch’s empirical models convert observable cooling infrastructure—such as the number and configuration of air-cooled chillers or cooling towers—into estimates of total cooling capacity and, from there, total facility power. For the Colossus facility, Epoch’s energy calculations and estimates range from approximately 200-500 MW, which is in line with the published expected capacity of 300 MW. While these estimations are broad and highly variable, Epoch’s work demonstrates how satellite imagery of cooling equipment can be used to infer broader operational characteristics of large AI data centers, even when direct disclosures are limited.

Support and Administrative Infrastructure

There is a large parking lot located to the west of the facility, visible as a large gray paved area with multicolored vehicles parked in lines. Just south of this parking lot, there is an additional unpaved open lot with white infrastructure, which are likely mobile container units. This area is likely being used for storage or other construction-related purposes. This is further evidenced by the open nature of the lot and the other mobile features parked in the area. This is notable due to the fact that, even as the building is operational, construction or upgrading activity may still be ongoing. Therefore, even after an official operational date is announced and comes to pass, this does not indicate the end of development activity at a site overall.

Recommendations

Recommendation 1. AI researchers and analysts can use this report as a guide for assessing data center buildout and operation.

Using both the established construction milestones and the identifiable features at completed data centers, the AI research community can reproduce these methodologies to compare construction milestones to commercial announcements, identify data center features, estimate buildout timelines, and evaluate potential energy usage requirements. 

Recommendation 2. Policymakers should integrate satellite imagery monitoring into assessments of foreign and domestic hyperscale data center buildout to support energy planning, competition analysis, and strategic forecasting.

This is particularly useful for monitoring the progress of lower-transparency countries such as China, Saudi Arabia, and the UAE.

Recommendation 3. U.S. state governments and civil society actors should use EO imagery as a layer of independent verification to ensure that frontier AI data center developers are adhering to their legal obligations.

Comparing satellite imagery to permits, environmental claims, and commercial announcements can empower local communities to hold data center developers accountable.

Recommendation 4. International organizations should consider integrating satellite imagery as one element of verification for future international agreements.

As global discussions of international AI governance continue, satellite imagery should be included as a tool for independent verification of future agreements. The International Atomic Energy Agency has a satellite imagery analysis team for nuclear safeguards verification purposes, and this displays the efficacy of satellite imagery as one element of infrastructure development and operation evaluations.

Conclusion

Data center facilities are critical to the successful operation of AI models, and their recent expansion reflects high interest in the continued development of these systems. However, despite public attention, key elements of data center construction and operation remain poorly understood due to a lack of publicly-available information, with corporate announcements being scarce and commercial timelines not necessarily reflecting true on-the-ground activity. This research demonstrates that EO satellite imagery can provide an independent, credible layer of insight regarding data center layouts, making it a valuable tool for verifying construction milestones and the presence of visible infrastructure rather than for measuring compute or internal activities.

The UAE Ajman Data Center case study exposes inconsistencies between construction milestone announcements and observable development progress, outlining the limitations of solely relying on corporate information for tracking data center buildout. At xAI’s Colossus facility in Memphis, EO imagery is used to identify specific features unique to data center facilities. In particular, the characteristics of power and cooling infrastructure support calculations of energy capacity and can be cross-referenced with public data such as permits and utility publications to ensure compliance.

While EO imagery is useful for tracking infrastructure-level developments, it is also limited by several constraints. It cannot be used to see the internal activity of data center facilities, and thus is ill-equipped to inform on GPU other compute activity. Current methodologies for estimating energy usage are still broad and exploratory, necessitating analytical inferences and requiring validation with other sources. Thus, satellite imagery should not be evaluated alone but should be treated as one of many analytical resources for assessing data center facilities.

These findings provide assessments to address global competition concerns, support evidence-based planning of industrial policies, and can contribute to longer-term international discussions of transparency and verification of AI-related infrastructure. From individual researchers to international organizations, satellite imagery can be integrated at many levels to support verification efforts as one facet of a larger toolkit of transparency-building measures.

Ultimately, this report illustrates where satellite imagery adds value—and where it does not—to inform future AI policy and governance efforts. As AI infrastructure expands, its physical signatures will continue to play a vital role in policy and regulatory discussions, and, when analyzed critically and integrated with other sources of data, it provides valuable, credible insight into the pace and scale of AI development.


Appendix