Document analysis · Resolution 26.08.02
What Aqua’s Pacifico feasibility study actually proves
Aqua tabled proposed Resolution 26.08.02 on August 4. The engineering report answers a narrow question: whether a future system can deliver the developer’s submitted demand—23 LUEs, with a 14-gpm peak and no fire flow. It does not independently establish the full potable-water need of the power plant and data center.
August 4 Board outcome
Aqua tabled Item 13. Resolution 26.08.02 was not approved.
Aqua confirmed the vote in an official announcement and posted the proposed resolution marked DRAFT and TABLED with blank signature lines. Approved August minutes and any return date remain pending.
The central finding
This is not a total water-feasibility study for the campus.
It is a conditional hydraulic and capacity review of one narrowly defined Aqua connection. The report supports a finding that the modeled system—after completion of specified infrastructure—can convey the requested 14-gpm peak at adequate pressure.
It does not establish the total water demand of the proposed 710 MW generation facility and approximately 490 MW data center, or show how cooling, fire protection, construction, wastewater, landscaping, and drought operations will be supplied.
What Aqua evaluated
A 23-home-equivalent request for a 2,841-acre power plant + data center development
Aqua’s packet lists 23 “LUEs Requested,” and the model says the anticipated demands were “provided by the developer.” In other words, 23 LUEs is the input Aqua tested—not an independently calculated estimate of the full development’s need.
What the model found
The proposed approach main can carry the requested flow.
The model reports 53 psi at peak hour and low velocity after adding a 13,340-foot, 8-inch approach main. Aqua plans to upsize that line to 12 inches through existing CIP project NU-3. Construction and easement costs remain listed as TBD.
The review standard
Eight issues Aqua should resolve before it acts
The realistic objective is not to claim that low-water technology is impossible or that Pacifico caused Aqua’s preexisting capital program. It is to make the public finding no broader than the evidence—and make the eventual limits enforceable.
01Service-rule record
The public application record is not auditable.
Aqua’s Water Service Tariff—its governing rules for water-service applications—requires a signed and sealed map or plat, detailed land uses, full-buildout average and peak demand for each land use, a buildout and demand schedule, fire-flow information, a project calendar, and on-site storage information. Aqua’s 12-page public packet omits the application exhibits, while the more detailed open-record production adds a conceptual plan but still does not supply a complete full-buildout water balance or final engineering package.
Before approval
Identify and publish every item submitted under Water Service Tariff §6.18—or table the request if required material was not supplied.
02Finding versus model
The proposed resolution says more than the study establishes.
The resolution says Aqua has sufficient capacity to provide water service “to the data center.” The model tests a specific potable request: 23 LUEs, 9 gpm maximum day, 14 gpm peak hour, and no fire flow. It does not test the total water needs of the data center and power campus.
Before approval
Limit the finding to the exact flow request and state expressly that total campus water feasibility was not evaluated.
03Demand basis
Twenty-three LUEs is a developer-supplied input—not an independently derived need.
The report lists 23 “LUEs Requested” and says anticipated water demands were provided by the developer. Aqua’s study tests whether its system can serve that figure; it does not derive or validate the figure from a campus water balance. A low-water design can be real, but the packet contains no cooling design, annual demand, separate source plan, or binding operating conditions showing how this 710 MW generation and approximately 490 MW IT campus stays within 14 gpm.
Before approval
Require a full-campus, all-source water balance tied to enforceable design assumptions and phase-by-phase limits.
04Customer eligibility
The customer, owner, tract, and end user do not line up cleanly.
The packet uses Pacifico Energy Development LLC and names Nayanika Dipak Panickar individually as “Developer.” The JETI applicant is Pacifico Cedar Creek LLC; its supplement says an unrelated third party will own and operate the data center; and BlackChamber appears on the data-center construction record.
Before approval
Establish the member, landowner, meter tract, end users, assignment rights, and correct large-volume service classification before approval.
05Contract governance
The unseen NSSA will contain the terms that make the number real—or meaningless.
Aqua’s governing service rules give the Board responsibility for approving water-service agreements and the general manager responsibility for negotiating and executing them. Resolution 26.08.02 would authorize negotiation and execution of the final Non-Standard Service Agreement without showing the Board or public its material terms.
Before approval
Require the completed NSSA to return for Board approval at a posted meeting before it is executed.
06Engineering record
The copy reviewed does not show a compliant engineering release.
The Garver memorandum displays a typed PE name and date, but no visible engineer’s seal or signature and no Texas engineering-firm registration number. Aqua may possess a compliant original; the packet reviewed here does not show it.
Before approval
Publish the signed, sealed, dated final report with the registered firm name and number before relying on it.
07Capacity transparency
The future-capacity scenario contains a large undisclosed commitment block.
The Nuse Zone grows from 697 existing connections to 1,532 connections before Pacifico is added—835 previously committed LUEs that are not identified. The model then adds only 16 LUEs of projected growth before adding Pacifico’s 23.
Before approval
Publish the committed-development schedule, modeling horizon, capacity assumptions, and any TCEQ-approved alternative criteria.
08Excluded uses
Fire, construction, wastewater, and drought remain outside the analysis.
“Fire Flow Request: None” is not a fire-water plan. The study also does not address initial tank filling, emergency replenishment, construction water, dust control, landscaping, wastewater, drought curtailment, or the interaction with any on-site well.
Before approval
Make service conditional on source-specific fire, construction, wastewater, cross-connection, and drought plans.
Aqua’s own service rules
Aqua’s service rules require the inputs needed to test the 23-LUE claim
Section 6.18 of Aqua’s Water Service Tariff—its rulebook for water-service applications—says a large-volume, commercial, or industrial applicant must submit the following. The public packet does not show most of it. Those records may exist elsewhere in Aqua’s files; the Board should identify and publish them before voting.
- Completed feasibility-study request
- Signed and sealed map or plat
- Detailed intended land uses
- Estimated LUEs
- Full-buildout average and peak demand by land use
- Buildout and water-demand schedule
- Fire-flow quantity and duration, if requested
- Design, plat, construction, phasing, and occupancy calendar
- On-site storage and pressurization information
The demand question
Twenty-three LUEs is an extraordinary outlier—not proof of impossibility
Water demand varies by orders of magnitude depending on cooling technology and operating rules. That makes the missing design assumptions more important, not less.
| Project or benchmark | Published water figure | What it shows |
|---|---|---|
| Pacifico / Aqua | 23 LUEs · 14-gpm peak hour | Developer-supplied demand; cooling design and annual volume not disclosed. |
| EdgeConneX / Aqua | 350 LUEs · 210-gpm maximum | Fifteen times Pacifico’s requested maximum flow. The campus covered by Aqua’s agreement is a roughly 130-acre, data-center-only project; Pacifico combines a data center and 710 MW power plant across 2,841 acres. |
| Sabey / Round Rock | ≈3.8-gpm annual average (2.0M gallons/year) | Very low use is possible; Round Rock also makes closed-loop cooling and no continuous cooling-water draw binding requirements. |
| El Paso full buildout | ≈1,042-gpm average · ≈1,736-gpm maximum day | A different hyperscale design can require orders of magnitude more water. |
The figures are normalized to gallons per minute for scale, but they are not identical demand measures: Pacifico is peak hour, EdgeConneX is maximum flow, Sabey is observed annual average, and El Paso reports average-day and maximum-day allocations.
Even the peak-flow ceiling implies extremely low site water use.
If the entire 14-gpm peak were consumed continuously all year, it would equal about 7.36 million gallons. Assigning every drop to a continuously operating 490 MW IT load—an intentionally generous assumption—produces an implied site WUE of about 0.0065 liters per kWh.
LBNL reports a U.S. data-center average just above 0.36 L/kWh and published hyperscale values of 0.1–0.3 L/kWh for some low-water airside-economizer and adiabatic systems. Pacifico’s implied ceiling is roughly 15–55 times lower than those reference points.
LBNL 2024 data-center reportLow water is technologically plausible.
Pacifico’s JETI filing identifies air-cooled / fin-fan equipment for the generation plant. Air-cooled data-center systems can also use little or no cooling water, usually with an energy tradeoff.
The defensible conclusion is therefore not that 23 LUEs must be false. It is that Aqua has not published the design or binding conditions that make the number credible for this project.
The missing engineering bridge
A full-campus water balance should reconcile every use and every source.
The study can be adequate for a 14-gpm connection only if the public record shows what that connection serves, what it does not serve, and where all excluded water comes from.
- Data-center cooling and humidification
- Power-plant cooling and auxiliary uses
- Turbine washing, inlet cooling, fogging, and emissions-control water
- Initial equipment and fire-tank filling
- Fire suppression and emergency replenishment
- Sanitary demand and wastewater generation
- Construction workforce, concrete work, and dust control
- Landscaping and long-term site maintenance
- Every Aqua, groundwater, trucked, reused, and nonpotable source
- Average, maximum-day, peak-hour, and annual demand by phase
The controlling contract
The final NSSA should return to the Board in public
No clear rule requires a completed NSSA before an initial feasibility decision. But Aqua’s governing service rules say the Board approves water-service agreements, while the general manager negotiates and executes them. The final contract is where the 14-gpm claim must become enforceable.
Valid for 90 days—through approximately September 24, 2026.
Resolution 26.08.02 is not approved; its signature lines remain blank.
Any renewed vote or NSSA process requires another posted action.
The NSSA should contain, at minimum:
- A hard 9-gpm maximum-day and 14-gpm peak-hour limit
- Daily, monthly, and annual volumetric ceilings
- Automated metering and an enforceable flow restriction
- An express list of which uses may—and may not—draw Aqua water
- No increase without a new feasibility study and Board vote
- No assignment to a tenant, affiliate, purchaser, or successor without Board approval
- Identification of every other source and cross-connection protection
- Binding drought curtailment without preferred industrial status
- Developer payment and financial security for dedicated facilities and easements
- Public reporting of aggregate monthly consumption
Three unresolved threshold questions
Who receives the water, what protects the site, and what is the final engineering record?
One meter cannot obscure multiple owners or uses.
Aqua’s study lists six appraisal accounts. Pacifico’s JETI filing lists eight, adding parcel IDs 90755 and 92335. If Aqua intends to use Single Owner Large Volume Service, its tariff limits that class to facilities on one tract owned by one person or entity and bars water purchased for resale.
Aqua should identify the landowner, member, meter location, power facility, data-center end user, and any transfer or submetering arrangement before it decides eligibility.
“No fire flow requested” does not answer the fire-water question.
A project-owned tank or separate source may be entirely appropriate. The packet simply does not disclose tank capacity, initial filling, refill rate, pump and hydrant design, emergency replenishment, or fire-authority approval.
The same gap applies to the projected peak construction workforce, dust control, potable water, and wastewater handling.
The Board should rely on a visibly final professional document.
Texas engineering guidance says released reports must be signed, sealed, and dated, and must identify the registered engineering firm and firm number. The reviewed copy does not display those elements.
That is a request for the proper final copy—not a claim that no such copy exists.
Texas engineering-board guidanceThe reasonable public ask
Publish the record, narrow the finding, and bind the limits.
Aqua can evaluate an eligible customer’s connection without declaring that it has established the water feasibility of an entire data center and power campus. Before any future action, it should publish:
- The complete §6.18 feasibility request and every attachment.
- A PE-certified, all-source water balance and the engineering basis for 23 LUEs.
- The fire-water source, storage, refill rate, and authority-having-jurisdiction approval.
- A signed and sealed final feasibility report with the firm registration number.
- The draft and final NSSA, with enforceable flow and volume limits.
- The 835 previously committed Nuse Zone LUEs and the model’s growth horizon.
- An itemized estimate for project-specific construction, easement, and meter costs.
- Any TCEQ-approved alternative capacity criteria relied upon in the engineering analysis.
- The exact customer, owner, meter location, parcel scope, end users, and assignment rights.
- Construction, wastewater, drought, groundwater, and cross-connection plans.
A finding the record can support
Replace the campus-wide claim with the connection Aqua actually studied.
Aqua’s engineers determined only that, following completion of the identified improvements and satisfaction of all regulatory conditions, Aqua may be able to provide a potable-water connection capped at 9 gpm maximum-day and 14 gpm peak-hour demand. The determination excludes fire flow and does not establish the total water requirements or overall feasibility of the proposed data center or power-generation facility.
Primary and technical sources
Read the underlying record
Aqua's tabled Resolution 26.08.02 packetAqua Water Service TariffAqua’s EdgeConneX agreement statementBastrop County–EdgeConneX project agreementAqua Drought Contingency PlanTCEQ minimum water-system capacity ruleLBNL 2024 U.S. Data Center Energy Usage ReportCity of Round Rock data-center water disclosureCity of El Paso data-center water disclosurePacifico JETI application J0049Texas engineering release guidance