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Reporting on Texas campus decisions
Interconnection, water, approvals and capital: the decisions that determine whether a data center campus phase moves.
Texas elected a new governor, a new railroad commissioner, a new comptroller and a new attorney general. The TCEQ rules a campus is built against did not change with them.
The 2026 election changed the governor, one Railroad Commission seat, the Comptroller and the AG. TCEQ's permit rules need an appointment and a reopened rule project to move.
October 29, 2026Fort Worth's water utility now requires closed-loop cooling and a wastewater pretreatment permit for new data centers in its service area
Since Aug. 11, 2026, Fort Worth's water utility has required closed-loop cooling and a pretreatment permit for every new data center in its service area.
October 24, 2026Can Texas counties stop data centers? Mostly no. Their say comes through roads, plats, flood rules and tax abatements.
A Texas county's real say over a data center comes through the approvals a site needs from it, such as road closures, plats, flood rules and tax abatements.
October 22, 2026TCEQ is screening data center authorizations claimed without a permit. Its letter never names backup generators.
TCEQ's Oct. 19 data center letter says it is screening claimed authorizations and names no rule. Generators within §106.511's limits need no registration.
October 19, 2026TCEQ has halted data center applications for construction stormwater coverage, which an operator needs before grading a large campus site
TCEQ says the Governor's data center permit halt covers Construction General Permit applications, the coverage large-site operators need before grading.
October 16, 2026Returning the TWDB survey doesn't put a campus outside the AG's investigation
The Texas Attorney General said Oct. 15 it has issued letters to 156 data center developments in 32 counties seeking up-to-date, accurate water-use data.
October 12, 2026Co-located net metering isn't firm before PUCT approval
PUCT decided Docket 59115 under PURA §39.169; its Order says §25.205 does not apply to that pre-rule filing. Underwrite approval and hold-harmless risk.
October 2, 2026How a Texas utility on the ERCOT grid bills your CIAC and returns your financial security
A Texas utility on the ERCOT grid bills your data center's CIAC ahead of the work and returns your financial security in stages starting at energization.
October 2, 2026Your campus is still provisionally classed. CapEx that assumes a final base or studied seat before verification cures is sequencing construction interest against a flip risk.
Batch Zero classification issued September 3, 2026 was provisional. ERCOT Market Notice M-A080326-04 ties conditional inclusion to verification, dynamic-model cures, or a PUCT good-cause exception; failure may disqualify the Large Load. Base-to-studied flips use Planning Guide §9.3.1(2)(a). Sequence irreversible land and long-lead CapEx against Oct-Nov Verification cure and the December Eligibility Verification Report, not a provisional label.
October 1, 2026Oct 12 is not another Batch Zero exhibit clock. It is the State and Community Impact RFI.
Campus capital still prices ERCOT's October 12 State and Community Impact RFI like optional paperwork beside Batch Zero Verification. Market Notice M-B091426-01 requires a complete RIOO package and notarized attestation by 5:00 p.m. CPT October 12, 2026; non-response is reported to the PUCT and Governor. Section C water answers are TWDB-authorized under §16.012.
October 1, 2026The rule accepts three forms of interconnect security. The election is a liquidity, rating, and bank decision, not a checkbox.
Under adopted 16 TAC §25.194, interconnect financial security may be posted only as cash collateral, a rated guaranty, or a rated letter of credit. Cash can credit intermediate→SLLIA; guaranty and LOC return at allocation. Batch Zero Verification Load Type E/G IFS trees then ask different evidence for each path. Instrument election is a liquidity, rating, and bank decision, not a checkbox.
September 30, 2026Every invoice in the draw can check out and the campus can still be a million dollars short of finishing the switchyard.
On a customer-built or build-transfer switchyard, reconciled invoices are not a cost-to-complete test. Available funding after the draw must cover forecast cost to complete; restricted interconnection security is not budget; retainage is not free contingency; TSP-accepted scope is a second gate. Worked example from Sitebraid handbook SB-DRAW 3.2.0.
September 30, 2026Your capital release still treats "financial security posted" as one checkbox. The Verification RFI Exhibit List splits it across three submitters.
The BZ Verification RFI Exhibit List splits site control and financial security across ILLE, TSP, and DSP exhibit rows. An ILLE deed does not cover the FS row; TSP ACH and DSP LOC confirmations are separate utility exhibits. Capital that treats "financial security posted" as one checkbox fails the 10-Business-Day package.
September 29, 2026A missed TWDB water survey is a criminal offense and a Chapter 11 permit bar under state law, and the Governor ordered enforcement. Oct 14 was the deadline for TWDB's first enforcement update.
Under TEX. WATER CODE § 16.012(m), failure to complete and return the TWDB water-use survey is a criminal offense, and failure to timely return bars TCEQ Chapter 11 permits. Governor Abbott's September 14, 2026 letter ordered TWDB to enforce those remedies. October 14, 2026 was the deadline for TWDB's first enforcement-progress update to the Governor, not a permit green light.
September 29, 2026Behind 265.5 MW of wind, Texas approved 525 MW of load. Curtailment is not capped by paired gen.
Docket 59220 (PURA §39.169): the 260 MW Crusoe Two Load must fully curtail on ERCOT emergency instruction, on top of Crusoe One. Paired gen is no cap.
September 27, 2026Two Texas pauses hold up data centers: TCEQ permits and ERCOT approval to energize
TCEQ says it has paused permits for infrastructure directly supporting data centers. ERCOT paused approvals to energize new data centers of 75 MW or more.
September 24, 2026The cascade that breaks data center developers: Oracle, force majeure, and the Texas projects already in the same trap
Oracle invoked force majeure on Project Jupiter after a pipeline permit denial slipped the power supply date. In Texas, the same cascade runs through ERCOT interconnection reclassification: 158 projects with studied load status have no confirmed energization date, and capital stacks closed against base load assumptions carry the same debt service gap.
September 18, 2026The fee everyone was budgeting for is gone. The money did not get cheaper.
The PUCT adopted 16 TAC 25.194 and removed the non-refundable interconnection fee. What replaced it is a returnable balance released at 20 percent of the remaining amount, against milestones in an SLLIA form the commission has not yet written.
September 17, 2026The filing that decides your project is one you are not allowed to submit
ERCOT is asking Batch Zero developers to prove they own their land and posted their money. The ten day clock, the portal account and the submit button all belong to the utility, and exclusion is written against the outcome rather than the effort.
September 14, 2026You cannot sell the capacity. You can sell the project that holds it.
Texas prohibits reassigning transmission capacity, but the interconnection request transfers with the entity. What recovery looks like when phase 2 has already stalled, priced against a recent Texas transaction.
September 14, 2026Four instruments decide what a stalled phase 2 costs you, and you have signed all of them.
Posted security under a tiered ERCOT rule most analyses report backwards, a non-utilization clause in your own tariff, a hedge sized to a drawdown that may not happen, and the covenant test after phase 2 slips.
September 14, 2026Most campus budgets have two categories for shared works. The money is in the third.
Build to plan or phase-gate is a false choice. What the retrofit premium, the forfeited queue slot and the cost of preserved optionality actually come to on a 240 MW growth increment, and which works belong in which column.
September 14, 2026Your electrical position gets examined. The water contract and the development agreement get signed.
Impact fees, water service agreements, Chapter 380 clawbacks and district assessments are all sized to full campus buildout and reviewed with a fraction of the scrutiny the substation gets. What executed Texas agreements actually say when the buildout does not arrive.
September 14, 2026You underwrote the tenant's credit and the tenant's power. You did not underwrite the tenant's lender.
A tenant that performs on phase 1 and declines phase 2 leaves no breach to declare and the shared works on your balance sheet. What the shift from cash flow to debt financing means for phase-gating, correlated slippage and the twenty-four month ERCOT milestone.
September 13, 2026A water-use survey is now an ERCOT gating item
Texas water agencies told a Senate committee that responding to their water-use surveys is now a de facto prerequisite for ERCOT interconnection approval. What Batch Zero classification did and did not test.
August 26, 2026The words tenant, lessee and occupant appear zero times in the rule that allocates your megawatts
ERCOT attaches one Batch Zero allocation to one entity behind one point of interconnection, and never says how a campus divides it among tenants. What that means for apportionment, milestone risk and lease drafting.