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Case File · Indiana · Marshall / White / Putnam / Starke Counties
Marshall County started it in February 2025. White County followed 2-1 on October 20, 2025. Putnam bundled data centers with wind, solar, and small modular reactors in November. Starke County's Planning Commission unanimously approved on December 4, 2025 — blocking any DC over 5,000 square feet. One county at a time, rural Indiana closed the door on hyperscale data centers.
RealClear would score the Indiana rural-county DC market 38/100 pending HB 1333 resolution.
4
Counties Blocking
10 mos
Timeline
2-1
White Vote
5K sq ft
Starke Threshold
HB 1333
State Backstop
38/100
RealClear Score
Rural Indiana · February 2025 — December 2025
From Marshall County's first domino to Starke County's Knox High School hearing. Every commissioner, every vote, every rationale.
February 2025
Marshall County passes the first Indiana data-center moratorium
Marshall County becomes the first Indiana county to pass a data-center moratorium. Commissioner Stan Klotz explains the rationale: 'Basically, we didn't like what we saw going on around us in other areas, and we just weren't quite totally sure how to respond.' The moratorium is defensive — triggered by DC activity elsewhere, not a specific local proposal.
October 20, 2025
White County passes moratorium 2-1 — Smolek dissents
The White County Board of Commissioners votes 2-1 to pass a data-center moratorium. Commissioner Kaleb Pass votes yes: 'That's a big job as we are learning to come up with every scenario to manage something like this.' Commissioner Mike Smolek dissents, arguing: 'We've had a moratorium on wind and solar for almost a year now. Has anybody come forward and said, Hey, this is what we need to change?' Smolek's dissent is substantive — he sees moratoriums as symbolic, not actionable.
November 2025
Putnam County passes one-year moratorium covering wind, solar, DCs, SMRs
Putnam County passes a one-year moratorium covering wind, solar, data centers, and small modular nuclear reactors. The Indianapolis Business Journal reports the combined-moratorium structure signals that Putnam is bundling all large-capex infrastructure under a single hold. Any single-use exception would be a concession to one operator type at the expense of others.
November 2025
Bryce Gustafson (Citizens Action Coalition) frames the risk
Bryce Gustafson of Citizens Action Coalition, a multi-county advocacy organization, states publicly: 'Once the barn door gets open on that stuff, it makes it easier for the horses to get through.' The framing treats moratoriums as the defensive posture and any approval as a permanent market opening — a zero-tolerance stance that sustains cross-county mobilization.
November 26, 2025
InkFree News: three Indiana counties with moratoriums
InkFree News reports that Marshall, White, and Putnam Counties have all passed data-center moratoriums. The cross-outlet confirmation (alongside Indianapolis Business Journal) solidifies the pattern as a statewide rural policy wave.
December 4, 2025
Starke County Planning Commission unanimously approves moratorium
The Starke County Planning Commission unanimously approves a one-year moratorium on Thursday December 4, 2025. The meeting is relocated from the planning commission office to Knox High School's auditorium to accommodate the crowd of residents opposing potential DC development. The resolution blocks any DC proposals exceeding 5,000 square feet. Local businesses and hospitals can still construct smaller supplementary facilities under that limit.
December 4, 2025
Planning VP Mark Allen signals a permanent ban may follow
Mark Allen, vice president of the Starke County Planning Commission: 'I know all three county commissioners very well. So, I have a feeling this will be — this moratorium will go on and then we're going to take the time and put probably some type of stop if we can by statute in Indiana.' Planning Commissioner Howard Bailey separately expresses support for pursuing a long-term or potentially permanent ban.
December 15, 2025
Starke County Commissioners scheduled to vote on final adoption
The Starke County Commissioners are scheduled to vote on final adoption of the moratorium resolution on December 15, 2025. Planning vice president Allen's pre-vote comments strongly imply the commissioners are aligned to approve.
2026 Legislative Session
Indiana HB 1333 pending — state preemption question
Indiana House Bill 1333 is pending in the 2026 legislative session. Senator Eric Koch has separately authored legislation allowing power plants to bypass local zoning on sites with existing energy facilities or former mines — passed, but explicitly excluding wind and solar. The Indiana General Assembly is the critical variable: state-level preemption could override the rural county moratoriums, but has not yet done so.
The Officials Who Decided These Cases
Four counties, four planning bodies, one multi-county advocacy organization. And one commissioner dissenting because moratoriums become symbolic.
Stan Klotz
Marshall County Commissioner / Zoning Board
Marshall County, IN
Documented Record
Publicly stated: 'Basically, we didn't like what we saw going on around us in other areas, and we just weren't quite totally sure how to respond.'
His framing is defensive and imitative — Marshall County's moratorium is triggered by DC activity elsewhere, not a specific local filing. This is the template for the three subsequent county moratoriums.
Kaleb Pass
White County Commissioner
White County, IN
Documented Record
Voted yes on the White County moratorium October 20, 2025, stating: 'That's a big job as we are learning to come up with every scenario to manage something like this.'
His framing — 'learning to come up with every scenario' — is the characteristic rural-commissioner posture: defer, study, pause. This is not aggressive opposition; it is precautionary governance that functionally blocks commitment.
Mike Smolek
White County Commissioner (Dissenter)
White County, IN
Documented Record
Voted against the White County moratorium 2-1, stating: 'We've had a moratorium on wind and solar for almost a year now. Has anybody come forward and said, Hey, this is what we need to change?'
The substantive dissenter on the White County 2-1 vote. His argument — that moratoriums are symbolic once adopted — is the most credible counter-position. Any DC operator targeting White County should understand that Smolek is the structural ally against moratorium inertia.
Mark Allen
Vice President, Starke County Planning Commission
Starke County, IN
Documented Record
December 4, 2025 statement: 'I know all three county commissioners very well. So, I have a feeling this will be... this moratorium will go on and then we're going to take the time and put probably some type of stop if we can by statute in Indiana.'
Explicitly signals that Starke County's moratorium is a placeholder for a permanent statute-based ban. Any DC filing during the moratorium window is effectively filing against a planning commission that has pre-announced its preferred long-term outcome.
Howard Bailey
Starke County Planning Commissioner
Starke County, IN
Documented Record
Expressed support at the December 4, 2025 meeting for pursuing a long-term or potentially permanent DC ban following the one-year moratorium.
Second Starke County planning commissioner on public record supporting a permanent ban. Two aligned commissioners on a planning commission is a structural majority signal for any future permanent-ban vote.
Bryce Gustafson
Program Organizer, Citizens Action Coalition
Documented Record
Publicly stated: 'Once the barn door gets open on that stuff, it makes it easier for the horses to get through.'
The multi-county advocacy organizer. His zero-tolerance framing sustains cross-county mobilization. Citizens Action Coalition provides the organizational infrastructure that connects isolated rural commissioners into a statewide pattern.
Eric Koch
Indiana State Senator
Documented Record
Authored legislation allowing power plants to bypass local zoning on sites with existing energy facilities or former mines — passed, explicitly excluding wind and solar.
A pro-siting state legislator, but his legislation excludes wind and solar and does not address data centers directly. A DC operator cannot rely on Koch-style bypass until HB 1333 or a successor statute explicitly addresses DC preemption.
Opposition Record
The opposition pattern is structural, not local — a single advocacy organization connected four isolated rural commissioner votes into a statewide policy wave.
Citizens Action Coalition
citact.org · Indiana statewide advocacy organization
Citizens Action Coalition connects isolated rural county commissioner votes into a statewide pattern. Program Organizer Bryce Gustafson provides the framing narrative, cross-county coordination, and sustained media presence. Their zero-tolerance posture — “once the barn door gets open, it makes it easier for the horses to get through” — sustains rural-commissioner political cover to impose moratoriums.
“Once the barn door gets open on that stuff, it makes it easier for the horses to get through.”
Starke County Residents
Knox High School auditorium · December 4, 2025
The Starke County Planning Commission meeting was relocated from the planning commission office to Knox High School's auditorium to accommodate the crowd of residents opposing data-center development. Venue changes are a quantifiable opposition signal: a commission that needs a high-school auditorium for a planning hearing is a commission that is not going to vote in favor of a DC.
Policy Contagion Pattern
Marshall → White → Putnam → Starke
Four rural Indiana counties passed or advanced data-center moratoriums in a 10-month window. This is a contagion pattern, not coincidence. A pre-filing analysis for any rural Indiana site must model the probability that the target county imitates its neighbors — and that probability rose with each successive moratorium passage.
The Pre-Filing Research
The pattern is the signal. Four counties in ten months is a market-level veto point, not four isolated local decisions.
Market Analysis
Indiana Rural DC Market
Marshall, White, Putnam, Starke — 4 moratoriums in 10 months
Regional Constraints
Jurisdictional Risk
Rural Indiana counties — moratorium pattern SPREADING
Definition Risk
Legislative Backdrop
Opposition Infrastructure
Recommendation
AVOID UNTIL HB 1333 RESOLVED. Four Indiana counties moved to block data centers in a 10-month window. This is a policy-contagion pattern, not isolated events. Any DC filing in a rural Indiana county now starts with a near-certain moratorium-amendment veto point. Wait for state-level resolution before committing capital to rural Indiana sites.
The Pre-Flight Checklist
Every risk that has made rural Indiana a cross-county veto ecosystem was visible in the public record before Starke County's December vote.
Cross-county contagion pattern — four in ten months
Market PatternMarshall February 2025, White October 2025, Putnam November 2025, Starke December 2025. A pre-filing analysis of rural Indiana in Q1 2026 would model contagion probability as a first-order risk, not a tail risk. The cadence is accelerating, not slowing.
Definition-deletion playbook — 5,000 sq ft Starke threshold
Zoning reviewStarke County's 5,000 sq ft threshold follows the Peculiar, Missouri playbook of using zoning ordinance definitions as veto points. Even a modest colocation facility exceeds 5,000 sq ft. The Zoning review would flag this threshold as effectively a full DC ban, notwithstanding the technical carve-out for hospitals and small businesses.
Citizens Action Coalition provides the connective tissue
Community risk reviewA single multi-county organization with a framed narrative and sustained media presence connects isolated rural commissioner votes into a policy wave. A pre-filing analysis would treat CAC's target list as a proxy for 'counties that will pass moratoriums next.'
Pro-DC state statute — HB 1333 — is pending, not passed
Legislative WatchIndiana HB 1333 could preempt local moratoriums but is not yet law. Senator Koch's bypass statute explicitly excludes wind and solar; its future applicability to DCs is open. A pre-filing analysis would not commit capital based on HB 1333 until it has passed both chambers and been signed.
Commissioner Smolek dissent in White County — structural ally
Political AnalysisCommissioner Mike Smolek's dissent in the White County 2-1 vote is the most substantive pro-reform position on record. His argument — that adopted moratoriums rarely generate follow-through action — identifies a specific political ally for any operator willing to work patient re-litigation.
Venue-change source record — Knox High School auditorium
Opposition MetricWhen a planning commission relocates to a high-school auditorium for a DC hearing, the political math is already decided. Venue-change records are hard evidence of opposition density — and a pre-filing analysis should weight them as veto-probability markers.
What Happened Next
The moratoriums are holding. HB 1333 is pending. And Indiana's urban DC corridors are now the structural winners.
Moratorium Status
Three Confirmed, Starke Pending Final
Marshall, White, and Putnam are confirmed in force. Starke County commissioners were scheduled to vote on final adoption December 15, 2025 — planning VP Allen's pre-vote comments signaled commissioner alignment.
State Variable
HB 1333 — Still Pending
Indiana HB 1333 could preempt local moratoriums but has not passed. The Koch bypass statute excludes wind and solar; its future DC applicability is uncertain. Any Indiana rural-county DC thesis is gated on HB 1333 outcome.
Structural Redirect
Urban Indiana Now the Winner
Meta's LEAP Innovation District in Lebanon, the Marion County urban corridor, and Google Indianapolis all operate outside the rural moratorium contagion. The effect is geographic concentration — which raises the implied value of urban Indiana sites.
The Lesson
Contagion Patterns Move Faster Than Projects
Four rural counties moved in ten months. A development timeline is 18–36 months. Pre-filing analysis must track contagion patterns as a market risk, not a site risk.
This Is Entitlement Research
Indiana is a contagion market. Site-level diligence misses contagion. Market-level diligence catches it — and that is RealClear's Comparable outcomes review job.
RealClear tracks cross-county contagion patterns, advocacy-organization reach, and state legislative posture — market-level source-record factors you cannot get from a single staff report.
Cited research summary · Not legal advice · Verify independently before making investment decisions
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