Starting next year, projects sited in tracts of rural land across the country will be newly eligible for a set of specific corporate tax benefits under a program expanded by the bill. The new rules “may significantly lower barriers for large-scale, capital-intensive projects in rural areas—most notably hyperscale data centers,” said a statement from Ways and Means Committee chair Jason Smith last year. “The economic case for building data centers in designated rural opportunity zones becomes far more compelling” with the new program, he continued. But experts warn that the results for rural communities could be mixed.

“Right now, the only requirement to get the benefits is capital investment,” says Emily Kraschel, a tax policy analyst at the Searchlight Institute, a public policy think tank. “However, that doesn't guarantee that that money is necessarily creating jobs or creating a local economic boost. You'd be more sure of that with a more traditional factory that requires lots of workers. But with a data center, that assumption goes a little wonky.”

During the first Trump administration, a bipartisan group of lawmakers proposed the creation of the opportunity zone program, which offers tax benefits for companies that choose to build projects in certain low-income census tracts. Last year, the One Big Beautiful Bill Act made a number of changes to open up the program in order to attract more investment to rural areas.

Kraschel and her colleagues from Searchlight have been researching data center projects that might qualify for these tax benefits, comparing the locations of data center projects in development with rural census tracts eligible for the new program. WIRED exclusively reviewed the research compiled by Searchlight and found more than 100 data centers under various stages of development in rural areas that could be eligible.

Searchlight used a very conservative database of under 700 data center projects that are planned or under construction to compile its research; other datasets put the number of data centers in development in the US at closer to 1,500. It’s very likely that the number of newly eligible projects is bigger, especially since more data centers are decamping from urban areas. Separate research from Pew found that while just 13 percent of operating data centers are located in rural areas, a majority of planned facilities—around 67 percent—are going rural.

Searchlight’s research comes as the backlash against data centers—including from rural and GOP voters—is reaching a fever pitch. Tax breaks for data centers being built by some of the most powerful companies in the world have become a flashpoint in these debates: Amazon recently made headlines for attempting to negotiate for a lower tax bill on one of dozens of data centers it plans to open in Mississippi, while The New York Times reported last week that Meta is writing off data center equipment under a federal tax break intended for research and experimentation.

In the scramble to try to regulate the industry, the opportunity zones aren’t going unnoticed. Last month, Senator Josh Hawley introduced legislation that would eliminate opportunity zone funding for data centers, claiming that he would help “ensure Big Tech companies don’t get tax breaks to build data centers on farmland.”A project simply existing in a rural opportunity zone doesn’t mean the company automatically will get the tax benefits; the company has to create a specialized investment vehicle to kickstart the process. Because the tax break can be considered confidential IRS data, it’s next to impossible to know which companies are pursuing the benefits unless they voluntarily disclose.

The research Searchlight compiled shows some big names that could stand to benefit from the program. But high-profile tech companies, when contacted for comment on the program, seemed eager to distance themselves from yet another tax break story. WIRED reached out to Meta, Amazon, Microsoft, and Google, all of which are developing data centers in areas that could be eligible for the new program, to ask about their plans to take the tax benefits.

Microsoft, Meta, and Amazon all denied using the program. In a statement, Microsoft’s general counsel of infrastructure legal affairs, Rima Alaily, told WIRED that the company “does not use the opportunity zone program to invest in the purchase or construction of its data centers.”Similarly, Amazon spokesperson Julia Lawless said the company “does not actively seek out” land in opportunity zones for development, and that it has not claimed the tax benefit for its projects.

“If we locate in one of these areas, it's because our site selection criteria—from available land to access to talent—aligns with tracts that governments across all levels have previously identified for economic development; not because we utilized the OZ benefit,” says Lawless. “We have not used this program for our site selection and have no plans to add it to our criteria for our future decisionmaking process."

Google did not respond. There are many reasons why data center builders may be choosing rural areas, from moving away from community opposition to pursuing cheaper land. But it’s not out of the question that companies with lower corporate profiles than Microsoft or Amazon developing data centers may choose to opt in to tax benefits.

Nathan Jensen, a government professor at the University of Texas-Austin, says that he would be “very surprised” if some companies were not considering siting in rural opportunity zones as part of their decisionmaking process. “It’s essentially free money,” he says.

Giving tax advantages to companies to build stuff to spur local economies is a good idea in theory. But the opportunity zone program has had mixed results in execution. There’s some evidence that the program has done little to actually drive investment to disadvantaged areas, and that many of the projects getting federal kickbacks would have happened even without the tax boost. (Overall, the government says the expansion of the opportunity zone program to rural areas will cost an estimated $40.9 billion over the next decade.)

There is no requirement for projects getting opportunity zone benefits to create jobs; the assumption is that they will do so, simply by siting in the community itself. This isn’t always the case for projects like storage facilities and warehouses, which, Jensen says, have been popular choices for developers working in opportunity zones. Data centers may create a number of jobs in the short term for their construction, but there’s an ongoing debate about whether or not they create a lasting new workforce over the longer term.

“Lawmakers need to decide what they really want out of these investments,” says Kraschel. “Do you want to use this as a way to get data centers away from population centers? Are they just looking for capital investment, or are they wanting things like jobs?”

Jensen, for his part, thinks it’s “interesting we have this program that's incentivizing an investment while states are trying to de-incentivize or even ban it.”

What We’re Writing On Friday, Amazon rolled out a series of commitments in communities where it’s building its data centers, pledging $1 billion in investments in initiatives like free community college programs over the next five years. Importantly, the company also confirmed that it is no longer using nondisclosure agreements with public officials in communities where it’s building data centers. NDAs have been a huge flashpoint in the public backlash to data center development across the country.

I wrote about Amazon’s announcement; it will be interesting to see if this changes public opinion! (If you live in a community near an Amazon data center and have thoughts about this, I’m all ears: molly_taft@wired.com, or reach me on Signal at mollytaft.76.) What We’re Reading There was a flurry of data-center-related activity on the Hill this week. First up: a long-awaited new bipartisan permitting bill has some big implications for data centers; Bloomberg has more.

And a bill echoing the White House’s Ratepayer Protection Act failed in the Senate, after Democrats claimed it was simply lip service to help Republican senator Jon Husted. Husted is facing a tough reelection battle against Sherrod Brown in Ohio, where data centers have played a starring role. NBC covers the battle.

In Pennsylvania, a data center is still struggling with local opposition even after offering residents $10,000 each to accept the project. The Wall Street Journal reports.

There’s a new tool that estimates the energy use and carbon emissions from data centers, created by Sustainable AI Group. (We spoke to cofounder Boris Gamazaychikov about AI agents and energy use for a newsletter a few weeks back.) You can read all about it in Heatmap.