---
title: "Justified Data Campus: water permits and construction milestones | Altss Blog"
description: "A permit-based analysis of Justified Data Campus, with two funding scenarios and a daily water-withdrawal example."
canonical: "https://altss.com/blog/justified-data-campus-water-permits-construction-timeline"
---

[Altss Research](https://www.linkedin.com/company/altss)

3 min read

Updated Nov 13, 2026

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# Justified Data Campus: water permits and construction milestones

A permit-based analysis of Justified Data Campus, with two funding scenarios and a daily water-withdrawal example.

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Justified Data Campus's June 2027 construction deadline precedes expected phased delivery. An investor must map permitted works to funded phases.

In its [July 6, 2026 filing](https://investors.terawulf.com/sec-filings/all-sec-filings/content/0001104659-26-080583/0001104659-26-080583.pdf), TeraWulf announced a 20-year Anthropic lease for approximately 401 MW of critical IT load through landlord Raylan Data LLC at the Hawesville, Kentucky campus. It expected phased delivery from late 2027 into early 2028. A [November 4 update](https://investors.terawulf.com/sec-filings/all-sec-filings/content/0001628280-26-069810/wulf-20261104.htm) gives the later schedule: late 2027 through the second quarter of 2028, with rent commencing on delivery of each data hall.

This case uses permit versions dated before October 15, retrieved November 13, and the separately dated November delivery update; later permit changes were not verified.

## Map construction to delivery

Kentucky's [Stream Construction Permit 37387](https://dep.gateway.ky.gov/eSearch.WebApi/api/documentGenerate/getDocument/14445191), for Justified DataPower LLC, runs through June 19, 2027. Covered construction must finish by then. Extensions are possible; its form calls for requests at least 30 days before expiry, or May 20 by calendar arithmetic. Engineering review should check the requirement to elevate HVAC and electrical equipment above the base flood elevation.

Consider two fictional plans, not reported Justified schedules or financing terms:

- Plan A: covered works finish May 31, 2027; commissioning continues into 2028. Completion evidence could support the related draw.
- Plan B: covered works continue until July 15, 2027. Before funding that work, the investor would require an approved extension or other valid coverage, rather than only a filed request.

Neither differing deadlines nor these fictional scenarios establish a breach or delay.

## Model water against the daily constraint

The [requirements for withdrawal Permit 0653](https://dep.gateway.ky.gov/eSearch.WebApi/api/documentGenerate/getDocument/14385505) authorize a year-round maximum of 2.0 million gallons per day across the specified three-well field. Monitoring and records are daily; reporting forms are due monthly by the 15th.

In a deliberately fictional forecast, six days at 1.0 million gallons and one at 2.4 million produce a 1.2-million daily average. The peak still exceeds a 2.0-million daily limit. This illustrates the measurement basis, not Justified's consumption.

For a proposed phase, an investor could request the peak-day estimate and its basis, including any simultaneous construction and operating demands. Averaging the forecast can conceal the day that needs a different supply or sequencing assumption.

During drought or emergencies, the Cabinet can change permit conditions temporarily. A Cabinet finding of harm to existing permitted users or other lawful water users triggers a requirement to change or stop withdrawals. A supply-restriction sensitivity case should therefore test the operating response without presenting the restriction as a forecast.

## Keep the construction-discharge term on its own calendar

The [KYR10U650 coverage letter](https://dep.gateway.ky.gov/eSearch.WebApi/api/documentGenerate/getDocument/14406018), addressed to Fluor for the Raylan Project, concerns construction stormwater discharges. Coverage takes effect on the letter's May 26, 2026 date and automatically terminates two years later, on May 26, 2028, unless an extension is requested beforehand or coverage is revoked earlier. The letter requires compliance with the master general permit.

That date falls within the updated delivery quarter. The relevant duration is the period of covered construction discharges. The letter does not document an operating cooling-water discharge authorization.

Power delivery can create its own cash trigger, as Altss's analysis of [AIB's utility-linked site purchase](https://altss.com/blog/aib-texas-data-center-site-utility-deferred-price) shows.

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