Health & safety gate
Pass, Pending or Fail. A failure cannot be bought off with points.
Policy prototype · Version 0.2 · August 16, 2026
A fair deal for communities—and responsible data centers.
Data centers are not all the same. A quiet, efficient campus on cleaner power is fundamentally different from a hybrid industrial campus built around utility-scale routine combustion. This proposal draws that line, makes health non-negotiable and makes public incentives earned.
The premise
Not anti-data-center. Anti hidden cost.
Many data centers look and operate like well-insulated business buildings. They can add tax base, fund services and create skilled work without making daily life worse. The recent move toward data-center campuses paired with large, routine gas generation is a materially different land-use, air-quality and public-health question.
A transparent rating gives responsible developers a reason to show their work early—and gives communities a principled alternative to treating every project as either harmless or unacceptable.
Architecture
Three decisions, kept deliberately separate
A single blended grade would let jobs or tax projections offset health risk. This design does not.
Community-impact level
Seven categories, 100 public-record points and visible unknowns.
Public consequence
Incentive eligibility, ordinary taxation, cost recovery or exclusion.
Evidence clears the gate
Independent, cumulative review of the whole campus demonstrates compliance with health-protective air, water, fire and safety criteria at maximum permitted operation.
Critical evidence is missing
No final safety conclusion. The project receives Level 4 treatment for incentive purposes until the developer supplies audit-ready evidence. Missing evidence is not itself proof of harm.
An objective threshold is not met
No incentive or public support. Under proposed state authority, the project could not build until redesigned to clear the gate. A local score alone cannot create that power today.
Community Impact Levels
A better project earns a better public bargain
These are community-impact levels, not Uptime Institute reliability tiers. Level 1 is best.
1
85–100 points
Community Asset
Eligible for the strongest performance-based, time-limited incentive—never an automatic entitlement.
2
70–84 points
Good Neighbor
Eligible only for a smaller, shorter incentive tied to verified performance and public reporting.
3
55–69 points
Pays Its Way
Pays ordinary taxes and receives no discretionary abatement. Full taxation is the baseline, not a punishment.
4
0–54 points
High Impact
No subsidy; pays ordinary taxes and all attributable infrastructure, monitoring and mitigation costs.
Level 1 also requires at least 20/25 in Air & Public Health and 8/10 in Transparency & Regulatory Integrity. Level 2 requires at least 16/25 and 6/10. A Pending gate overrides the numeric score and receives Level 4 incentive treatment; a failed gate is Excluded.
The 100-point score
What a developer must prove
The burden sits with the party seeking public permission, infrastructure and tax relief. No verified information, no public incentive.
25Air & public health
No routine local combustion, or independently modeled emissions and controls that protect health at maximum operation.
Complete permits, unit inventory, allowable and actual emissions, enforceable hours, cumulative dispersion analysis, monitoring and sensitive-receptor review.
18Grid, energy & climate
Adds verifiable clean or firm capacity, flexible load or exportable support without shifting infrastructure costs to other customers.
Interconnection studies, cost-allocation records, contracts, dispatch data, hourly energy sources and annual greenhouse-gas intensity.
12Water
Low-use or closed-loop cooling, drought protection, reuse and a complete campus-wide water balance.
All-source demand, withdrawals, consumption, discharge, fire water, phased buildout and enforceable drought limits.
12Noise & neighborhood
Quiet normal and emergency operation, appropriate siting, setbacks and responsive neighbor protections.
Receptor-level daytime, nighttime, tonal and low-frequency testing for normal, startup, shutdown and emergency modes.
15Fiscal value & jobs
Durable skilled jobs, full-cost infrastructure, independently tested net revenue and enforceable community benefits.
Actual jobs and payroll, taxes paid, every incentive, service costs, local hiring and performance-based clawbacks.
8Land, transport & safety
Compatible land use, protected habitat, safe truck routes and fully funded emergency response.
Final layout, drainage, traffic, fuel and battery hazards, fire water, mutual aid, evacuation and response capacity.
10Transparency & regulatory integrity
Timely, consistent whole-campus disclosure and compliance with the purpose—not only the narrow wording—of the law.
All phases, parcels, affiliates and dedicated generation; change log; independent audit; monitoring; prompt corrections.
Regulatory integrity
Compliance in the actual spirit of the law improves the score.
Baseline legal compliance is only the floor. Full credit requires a developer to disclose the whole practical project—every phase, affiliate, parcel, dedicated power source and maximum operating case—and to correct material changes before an agency or resident has to discover them.
- One campus record across grid-connected, behind-the-meter and islanded systems.
- Annual independent audit, public monitoring and a durable change log.
- Material omissions or threshold-splitting trigger a downgrade, ineligibility or clawback after due process.
- A scoring concern is not a misconduct finding; the record must support any such conclusion.
Expanded scorecard · Pilot evidence review
Local campuses, a Texas megaproject and better models—scored by the same rules.
These are provisional public-record assessments, not government certifications. Buildings and phases are aggregated into one practical campus; missing evidence receives no points until supplied.
ProjectPublic-record health screenEvidence scoreEvidence band
Pacifico Cedar CreekCedar Creek, TexasHealth gate pending18/100Level 4 treatment · IncompleteEdgeConneX Cedar Creek Campus 1FM 535 at Wolf Lane · Cedar Creek, TexasHealth review pending44/100Level 4 evidence band · IncompleteEdgeConneX Cedar Creek Campus 26682 / 6402 FM 535 · Cedar Creek, TexasHealth review pending30/100Level 4 evidence band · IncompleteAmazon / Pacifico GW RanchPecos County, near Fort Stockton, TexasHealth review pending39/100Level 4 evidence band · IncompleteCyrusOne Allen DFW3–5Allen, TexasNo trigger found*72/100Level 2 candidateMeta TempleTemple, TexasNo trigger found*74/100Level 2 candidateGoogle HaminaHamina, FinlandNo trigger found*88/100Level 1 candidateGoogle St. GhislainSaint-Ghislain, BelgiumNo trigger found*80/100Level 2 candidateOne campus, one score
Campus 1 includes the AU02 / AUS02 / CoreWeave phase inside the four-building Project Tango record. Campus 2 combines EDCAUS11 and EDCAUS12 with the reported broader buildout. We do not manufacture extra projects by counting every building, filing or tenant twice.
See the FM 535 corridor record →Texas finding: no Texas campus receives a final Level 1 from this public record. The two scoreable EdgeConneX campuses, Pacifico Cedar Creek and GW Ranch remain Pending and receive Level 4 incentive treatment. CyrusOne Allen and Meta Temple remain provisional Level 2 candidates with a visible path upward.
FM 535 watchlist
Visible, but not yet scoreable
No numeric score is better than false precision when the public record does not yet define a project. These entries are ineligible for any proposed incentive until a scoreable campus package exists.
EdgeConneX Cedar Creek Campus 3
6543 FM 535 vicinity · Cedar Creek, TexasCounty-sourced reporting describes an approximately 400-acre, up-to-nine-building concept within a 704-acre host parcel. No filed project boundary, building application or whole-campus environmental, utility and fiscal package was located. A locationless ECX AUS31–36 state registration is a useful signal, but it is not conclusive proof that the registration is this site.
Needed to score: A filed campus plan, controlled boundary, equipment and load schedule, water and power requests, generator inventory, noise and safety studies, jobs and incentive terms.
Amazon Cedar Creek land assemblage
South of FM 535 · Cedar Creek, TexasAmazon Data Services appears in the county land record, and the corridor map traces an approximately 1,300-acre CAD-derived assemblage. Land ownership is not a filed data-center plan. No campus boundary, development application or resource package was located, so assigning 0–100 points would imply a project definition the public record does not yet support.
Needed to score: A development decision and filed plan identifying the buildout, power, water, generators, noise, jobs, infrastructure and any requested incentives.
Cedar Creek, Texas
Pacifico Cedar Creek
Proposed data-center and gas-generation campus
Evidence score18/100 · Level 4 treatment · Incomplete
Health gate pending
The public record does not yet contain the full-buildout evidence needed to clear the health gate or justify a subsidy. This is not a finding that Pacifico violated the law or will cause a specific health outcome.
Air & public health0/25
Grid, energy & climate2/18
Water4/12
Noise & neighborhood0/12
Fiscal value & jobs7/15
Land, transport & safety2/8
Transparency & regulatory integrity3/10
Credit currently supported
- Filings disclose a 710 MW generation concept, about 490 MW of associated IT load and a multibillion-dollar investment model.
- The eligible-equipment list identifies air-cooled equipment and emissions controls; stormwater and air-registration records now exist.
- The applicant projects 25 permanent operations jobs and separates temporary construction employment in its revised model.
What blocks a better or final score
- The complete expedited air registration is not public: unit count and models, hours, pollutant-by-pollutant potential, enforceable limits and cumulative modeling remain unresolved.
- No verified grid-export or flexibility contract, complete water and fire-water balance, receptor-level noise study or full emergency-response plan is public.
- The original integrated behind-the-meter description and later generation-only / unrelated-data-center framing require a transparent whole-campus reconciliation.
Primary government recordJETI application J0049 and supplements
Primary government recordTCEQ air project 413471 / registration 185019
Utility filingAqua feasibility-study record
FM 535 at Wolf Lane · Cedar Creek, Texas
EdgeConneX Cedar Creek Campus 1
Four-building grid-connected campus · Construction / early operation unconfirmed
Evidence score44/100 · Level 4 evidence band · Incomplete
Health review pending
The record describes a conventional grid-connected four-building data-center campus—not Pacifico-style routine utility-scale gas generation—but it does not yet contain the audit-ready generator, noise, fire-water, grid-cost and energy-source evidence required to clear the gate. This is an incomplete-evidence finding, not a finding of a violation or specific health harm.
Air & public health12/25
Grid, energy & climate5/18
Water7/12
Noise & neighborhood3/12
Fiscal value & jobs8/15
Land, transport & safety5/8
Transparency & regulatory integrity4/10
Credit currently supported
- Bastrop County’s executed agreements define one four-building Project Tango campus; the state separately identifies CoreWeave as the registered occupant of the AU02 phase.
- The filed 578,000-square-foot building includes automatic sprinklers, and the operator publishes a phased campus power-and-buildout concept.
- Aqua publishes a 350-LUE / 210-gpm maximum service agreement with prerequisite upgrades funded by the developer rather than Aqua ratepayers.
What blocks a better or final score
- No campus-specific backup-generator inventory, enforceable runtime and air limits, interconnection cost allocation, hourly energy record or independent receptor-level noise study was located.
- The public record lacks an annual and drought-year water balance, complete fire-water and emergency-response package, and actual jobs, payroll and net-tax audit.
- The county agreements abate 75% of incremental county property tax per building for 10 years, and the campus participates in Texas’ 20-year sales-tax exemption program. Aqua also says EdgeConneX’s public ‘Regional Partner’ characterization was unauthorized and inaccurate; that disclosure issue blocks integrity credit without proving intent.
Primary county recordProject Tango Buildings 1–4 abatement agreements
Primary state recordAUS02 / AU02 construction filing
Primary utility recordAqua–EdgeConneX service statement
Primary state recordTexas qualifying-data-center register
Operator statementAustin campus operator sheet
6682 / 6402 FM 535 · Cedar Creek, Texas
EdgeConneX Cedar Creek Campus 2
Nine-building campus concept · Two buildings filed
Evidence score30/100 · Level 4 evidence band · Incomplete
Health review pending
EDCAUS11 and EDCAUS12 are building phases within one broader Campus 2 concept, so this score counts them once. The record supports their scale and sprinkler design, but not a campus-wide energy, water, air, noise, fire-response, tax, jobs or infrastructure-cost package. Missing evidence receives no credit; it is not proof of harm.
Air & public health10/25
Grid, energy & climate3/18
Water2/12
Noise & neighborhood2/12
Fiscal value & jobs6/15
Land, transport & safety4/8
Transparency & regulatory integrity3/10
Credit currently supported
- TDLR records identify two one-story, approximately 729,500-square-foot buildings, each with a $700 million filed estimate and automatic sprinklers.
- The Comptroller separately lists ECX AUS11–16 in the qualifying-large-data-center program with EdgeConneX affiliates as owner, occupant and operator.
- County-sourced reporting describes two current buildings and seven anticipated phases across a broader 951-acre concept, making the intended buildout visible enough to define the scoring boundary.
What blocks a better or final score
- No whole-campus load, interconnection study, cost allocation, energy source, backup-generator inventory, water request or drought plan was located.
- No receptor-level noise analysis, cumulative corridor study, final emergency-response and fire-water plan, traffic plan or complete controlled project boundary is public.
- Permanent jobs, payroll, actual taxes, incentives and net public-service costs remain unresolved. The two filed buildings and the broader nine-building concept should be reconciled in one auditable campus record.
Primary state recordEDCAUS11 construction filing
Primary state recordEDCAUS12 construction filing
Primary state recordTexas qualifying-data-center register
Independent local reportingThree-campus scope reported from county records
Pecos County, near Fort Stockton, Texas
Amazon / Pacifico GW Ranch
Planned hyperscale data-center and on-site generation campus
Evidence score39/100 · Level 4 evidence band · Incomplete
Health review pending
GW Ranch has a substantially fuller air-permit record than Pacifico Cedar Creek: TCEQ reviewed maximum-operation modeling for the 35-turbine power plant and found modeled concentrations below applicable air-quality standards. The broader campus still lacks the water, noise, battery-fire, emergency-response and incentive evidence needed to clear this scorecard’s gate. Pending is not a finding of a violation or predicted health outcome.
Air & public health14/25
Grid, energy & climate5/18
Water3/12
Noise & neighborhood3/12
Fiscal value & jobs6/15
Land, transport & safety3/8
Transparency & regulatory integrity5/10
Credit currently supported
- TCEQ’s record identifies 35 simple-cycle gas turbines, models routine operation for up to 8,760 hours per turbine annually, requires modern NOx and oxidation controls and includes pollutant-specific impact modeling.
- The initial private-grid design supplies its own generation rather than immediately placing a multi-gigawatt load on ERCOT. Pacifico also describes up to 1.8 GW of batteries and 750 MWac of solar, although those resources are not yet demonstrated.
- Amazon has confirmed the planned Pecos County campus. State construction filings document three initial data-center buildings at roughly 189,000 square feet and $300 million each; jobs and completion dates remain projections.
What blocks a better or final score
- The air authorization contains annual ceilings of approximately 2,830 tons of NOx, 5,955 tons of CO, 999 tons of particulate matter and 33.2 million tons of CO2e. These are permitted maxima—not forecasts or measured emissions—but the scale materially limits air, energy and climate credit.
- No complete campus water balance or groundwater authorization, drought limit, receptor-level noise study, battery-fire and emergency-response plan, traffic plan or full data-center backup-generation inventory was located.
- TCEQ describes a nominal 5,000 MW plant while Pacifico markets up to 7.65 GW of gas generation. Pacifico describes a private grid; Amazon says the campus is designed for a later grid connection. Those scopes, plus any abatement terms and infrastructure costs, require one reconciled public record.
Primary TCEQ air recordGW Ranch preliminary determination summary
Power developer statementGW Ranch scale and technology plan
Independent reporting with direct statementAmazon confirmation and project statement
Primary state recordAmazon Building A construction filing
Primary state recordAmazon Building B construction filing
Primary state recordAmazon Building C construction filing
Primary county recordPecos County June 22 agenda
Allen, Texas
CyrusOne Allen DFW3–5
Operating colocation campus
Evidence score72/100 · Level 2 candidate
No trigger found*
A useful Texas water-and-energy candidate: closed-loop air cooling avoids routine cooling-water demand, and a new Texas solar-and-storage project annually matches campus electricity. Annual matching is not the same as 24/7 carbon-free operation.
Air & public health18/25
Grid, energy & climate13/18
Water12/12
Noise & neighborhood7/12
Fiscal value & jobs7/15
Land, transport & safety8/8
Transparency & regulatory integrity7/10
Credit currently supported
- CyrusOne reports water-free, closed-loop air-cooled chillers and a net-positive-water certification for the Allen campus.
- A 67 MW Texas solar-and-storage transaction was sized to match the campus’s annual electricity use.
- The operator reports Three Green Globes certification and purpose-built fire-detection and suppression systems.
What blocks a better or final score
- No public site-level annual MWh or water dataset, grid-flexibility result, generator emissions and runtime audit or independent boundary-noise study was located.
- Official city records document a recommended 50% property-tax abatement for 10 years; permanent jobs and actual net taxes paid remain unresolved publicly.
- Most environmental performance evidence is operator-reported rather than a complete campus audit.
Operator statementAllen campus design and certifications
Operator transaction announcementTexas solar-and-storage transaction
Primary government recordCity of Allen incentive minutes
Temple, Texas
Meta Temple
Newly operating hyperscale campus
Evidence score74/100 · Level 2 candidate
No trigger found*
A promising Texas jobs-and-water candidate: the newly opened campus reports about 100 operations roles, closed-loop cooling and local water restoration. A full operating year is needed before the claims can be verified.
Air & public health18/25
Grid, energy & climate12/18
Water11/12
Noise & neighborhood8/12
Fiscal value & jobs10/15
Land, transport & safety7/8
Transparency & regulatory integrity8/10
Credit currently supported
- Meta reports more than $1.2 billion invested and about 100 operations jobs at the newly online campus.
- The operator says closed-loop liquid cooling uses no water for most of the year and supports 5.2 million gallons of annual regional water restoration.
- The City of Temple identifies the Polmer / Meta campus as complete and operational.
What blocks a better or final score
- The campus is too new to provide a full year of actual electricity, water, emissions, noise and emergency-generator performance.
- Renewable matching is not proof of 24/7 carbon-free power, and no verified demand-response or grid-contribution record was located.
- Bell County reports a 75% real- and personal-property abatement for 10 years tied to 40 jobs; actual net taxes and full incentive value remain to be tested.
Operator statementTemple campus opening and design claims
Municipal recordTemple data-center project registry
Primary government recordBell County 2024 financial report
Hamina, Finland
Google Hamina
Operating campus in a former paper mill
Evidence score88/100 · Level 1 candidate
No trigger found*
The clearest pilot example of a data center creating measurable public value: very high carbon-free electricity, a reused industrial site, hundreds of jobs, property taxes and useful heat returned to the city.
Air & public health23/25
Grid, energy & climate16/18
Water10/12
Noise & neighborhood10/12
Fiscal value & jobs13/15
Land, transport & safety8/8
Transparency & regulatory integrity8/10
Credit currently supported
- The City of Hamina reports 98% carbon-free electricity, about 500 workers, billions of euros invested and annual property tax measured in millions of euros.
- Google uses seawater cooling at a repurposed paper mill and supplies recovered heat free to the municipal district-heating system.
- Google and the local utility project the recovered heat can meet about 80% of the district network’s annual demand.
What blocks a better or final score
- Public sources reviewed do not provide campus MW, annual cooling-water withdrawal and discharge, backup-generator emissions or independent boundary-noise results.
- Finland treats the reduced electricity excise duty for qualifying data centers as state aid; the site-level benefit must be included in the net-benefit test. The city also reports no corporate-income tax in 2024–25 during continuing investment.
- A final certification would need a consolidated compliance record and audit-ready annual performance data.
Municipal recordCity of Hamina impact account
Operator statementHamina campus description
Operator + utility statementHeat-recovery project detail
Primary government recordFinnish electricity-duty state aid
Saint-Ghislain, Belgium
Google St. Ghislain
Operating hyperscale campus
Evidence score80/100 · Level 2 candidate
No trigger found*
A useful grid-and-water model: treated canal water avoids potable cooling demand, while a data-center battery supplies grid services and replaces part of the diesel backup fleet.
Air & public health19/25
Grid, energy & climate16/18
Water11/12
Noise & neighborhood8/12
Fiscal value & jobs12/15
Land, transport & safety7/8
Transparency & regulatory integrity7/10
Credit currently supported
- Google reports treated industrial-canal water, no energy-intensive chillers, on-site solar and a site PUE near 1.09.
- A 5.5 MWh battery replaces some diesel backup; 2.75 MWh is allocated to grid ancillary and demand-response services.
- Wallonia reports a large regional supplier and workforce footprint associated with the campus expansion.
What blocks a better or final score
- The most recent site-specific carbon-free-energy figure located was 82% for 2022; current load, energy mix and water volumes are not public in the reviewed record.
- The remaining generator inventory and runtime, emissions, boundary noise, actual taxes, incentives and consolidated compliance history need verification.
Operator statementBelgium campus performance
Technology-provider recordBattery grid-services project
Regional government recordWallonia investment account
* “No trigger found” means the pilot review found no disclosed routine utility-scale combustion or other fact that presently triggers a health failure. It is not a final certification. Each candidate still needs the complete evidence package required above. A low evidence score for a proposed project reflects what is not yet proved; it is not a prediction of harm.
Pacifico finding
Why the Cedar Creek record remains Pending
A 250-ton federal permitting threshold is not a public-health finding, and regional attainment status does not replace project-specific cumulative modeling.
Current public statusIncomplete
Health review pending · Level 4 treatment for incentive decisions
Pacifico’s filings describe multiple simple-cycle gas turbines and fast-start peakers totaling 710 MW, supporting about 490 MW of associated IT load. TCEQ received expedited Registration 185019 on August 14, 2026, but the complete registration was not public when this scorecard was prepared.
The score therefore aggregates the data-center load and dedicated generation for community-impact purposes. That is not a finding of common ownership or a Clean Air Act source-aggregation determination. It is the only way to keep practical impacts from disappearing across contracts, affiliates or property lines.
The Austin–Round Rock area remains legally designated attainment/unclassifiable for the 2015 ozone standard. TCEQ’s 2026 monitoring plan nevertheless reports a 2022–2024 design value of 0.072 ppm against the 0.070 ppm standard; more recent preliminary rolling data may be lower. The careful conclusion is that recent monitoring history leaves little margin for complacency—not that Pacifico has already been shown to cause nonattainment. Its contribution cannot be determined until the full emissions inventory and cumulative modeling are public.
A route to law
Start locally; finish with a statewide rule
The pieces can move at different levels without pretending counties already possess authority Texas law has not given them.
Use the score for discretionary incentives
Bastrop County can place objective criteria in its Chapter 312 guidelines and reserve its own abatements for better projects. Each taxing unit controls only its own relief, and existing signed agreements should be honored.
Create a binding health gate and statewide consequences
Require a TCEQ health-and-safety certificate, whole-campus reporting and PUCT/ERCOT findings; then link the public rating to JETI, data-center sales-tax exemptions, annual verification and clawbacks.
Turn the current audit into a durable public certificate
The June and August 2026 directives already ask many of the right questions. The permanent rule must also reach islanded, behind-the-meter and non-ERCOT campuses—not only projects advancing through ERCOT’s queue.
Authority matters
A county score can guide a county abatement; it cannot supersede a TCEQ authorization or create a general construction ban. A binding no-build health gate requires state legislation or authority expressly delegated by the Legislature. Only the Governor can call a special session, and his June directive publicly committed to legislation in the next session rather than announcing a data-center special session.
Policy record
Primary sources behind the proposal
This is Version 0.2. The weights, floors and scores should be tested by public-health, grid, water, fiscal and emergency-response experts—and revised in public.
Governor Abbott’s June 10 data-center directiveGovernor Abbott’s August 3 audit directiveTexas Chapter 312 abatement processTexas data-center sales-tax exemptionsTexas JETI application processTCEQ Austin-area air-quality statusTCEQ 2026 Annual Monitoring Network PlanUptime Institute Tier Standard (a different system)