Air permit deep dive & community action · October 12, 2026
Pacifico’s air permit: the pollution numbers need answers.
Our review finds a substantial emissions discrepancy and unresolved questions about how the proposed gas plant would be limited and monitored. Here is what the findings mean for Cedar Creek—and how to speak up tomorrow.
Start here
The numbers help decide how much scrutiny this gas plant receives.
Pacifico wants to build a gas-fired power plant near Cedar Creek to supply a proposed data-center campus. The August air application lists 48 turbines with a combined generating capacity of about 1,326 megawatts. Before the generating units can be built, the Texas Commission on Environmental Quality, or TCEQ, must authorize their air emissions.
Pacifico is seeking a standard permit, a route built around preset requirements. Its application says the plant would remain below the annual pollution threshold that triggers a more extensive federal review. Our new analysis tests whether the numbers and operating restrictions support that claim.
What we found
- Eight large turbines have an unresolved mismatch. The stated exhaust concentration and fuel input produce a nitrogen-oxides rate about 34% higher than the hourly rate used in the application.
- That difference can change the permitting result. A separate calculation using the application’s operating schedules and all 48 turbines reaches 263.98 tons per year before startup and shutdown, if the higher Ansaldo rate is applicable.
- The annual limits need a clear, enforceable basis. Assumed operating hours, pollution-control performance and startup/shutdown estimates need supporting evidence and a workable way to check compliance.
Our conclusion: TCEQ should reconcile these issues and document the basis for the requested permit before approval. The 263.98-ton result is a conditional calculation, not a final finding that the project must be classified as a major source.
On October 12, 2026, Lost Pines Watch emailed its technical comment and the attached “Pacifico Air Permit Emissions Analysis” to TCEQ’s Office of the Chief Clerk concerning Registration 185019 / Project 413471. We requested that the comment and complete attachment be placed in the application record and that the agency address the findings before approval.
Later on October 12, TCEQ’s Office of the Chief Clerk acknowledged our email submission. Brad Patterson replied: “Thank you. We will forward for processing.”
The review was informed by engineering work supplied by an analyst at the Environmental Integrity Project. Lost Pines Watch’s report includes its own calculations and interpretations; it is not presented as a formal report or endorsement by that organization.
This analysis examines the publicly released 54-page August application and the corrected independent workbook. TCEQ should identify any later revisions and show exactly how they resolve the findings. Read the full report, revised October 6, 2026.
Why this matters
“Minor source” is a permit category. It does not mean a small plant.
The application applies a threshold of 250 tons per year of any one regulated pollutant to the source as a whole. At or above that threshold, the federal Prevention of Significant Deterioration program—usually called PSD—requires more extensive review, including pollution-control evaluation, air-quality analysis and public participation.
The key quantity is potential to emit: what the plant could emit under its design and allowed operation, accounting for qualifying enforceable restrictions. A forecast that the owner will run fewer hours is useful only if the permitting basis actually makes the necessary restriction binding.
What does this mean for neighbors?
The calculation can determine which protections and public-review procedures apply. The 250-ton threshold is a permitting trigger, not a dividing line between safe and unsafe air. Annual tonnage alone does not tell us the concentration people would breathe at a particular home or school.
Nitrogen oxides, or NOₓ, are gases produced by fuel combustion. They help form ozone and particle pollution in the atmosphere. EPA explains their effects. That is why accurate estimates and effective controls matter long after construction ends.
Why the separate 100-ton threshold does not settle this question
Title V is a different operating-permit program. Pacifico already acknowledges that it would be major under Title V while claiming it would remain minor under PSD. Both classifications can apply to the same plant. Our review asks whether its claimed PSD status and standard-permit eligibility are supported.
The findings, explained
Five questions TCEQ needs to answer.
1. Why do the Ansaldo turbine numbers disagree?
The application gives two ways of describing the same turbine’s controlled NOₓ emissions: the concentration in its exhaust and the amount released each hour. Converting its stated concentration and fuel input gives about 6.52 pounds per hour, compared with the application’s 4.88 pounds per hour.
Across eight turbines at the listed annual schedules, that is a difference of 28.76 tons per year. Our calculation already uses the application’s stated concentration after pollution controls.
Why is this important?
A small-looking hourly difference adds up across thousands of operating hours and multiple turbines. It could move the source above the threshold for more extensive review. A valid equipment guarantee could support the lower rate, but TCEQ needs to show the evidence and reconcile the two representations.
See the annual comparison and its limits
Both totals count all 48 turbines and exclude startup/shutdown. They use the detailed worksheets’ operating schedules, including the lower SMT60 schedule. Those schedules are calculation assumptions, not established operating caps.
The application’s separate published 233.61-ton figure includes startup/shutdown and contains an apparent counting error. It is not the baseline for our 263.98-ton calculation.
The maximum exhaust concentration and maximum fuel input may occur under different conditions. TCEQ needs operating data or equivalent guarantees showing which values occur together and the maximum mass emissions across the allowed range. The application also shows a similar proportional mismatch for carbon monoxide, making the underlying conversion basis worth checking.
2. Are all the turbines counted—and which operating hours apply?
The application lists eleven Solar PGM70 turbines, but its NOₓ subtotal matches multiplication by six. Correcting that count adds approximately 6.65 tons per year to the published total. Separately, the Solar SMT60 summary lists 8,760 normal operating hours, while its detailed annual calculation uses 4,380.
What does this mean?
A permit decision needs one consistent equipment list and one defensible operating basis. A spreadsheet can look precise while leaving units out or using conflicting schedules. The PGM70 correction is already included in our 48-turbine reconstruction; it must not be added to 263.98 tons a second time.
3. What actually keeps annual emissions below the threshold?
The worksheets use reduced operating schedules, but also say those scenarios are not limits on maximum hours, startup/shutdown events or gas firing. Other application representations can become permit conditions, so this wording does not prove that every restriction is unenforceable.
TCEQ should identify the binding hourly and annual limits, their averaging periods, and how actual operation will be measured, recorded, reported and enforced.
Why is this important?
If permission to emit less depends on running fewer hours or keeping controls effective, the authorization must establish those limits and a credible way to detect when they are exceeded. Multiplying operating hours by an unsupported hourly rate would not reliably tell us how much pollution was released.
4. What supports the startup and shutdown estimates?
Startup/shutdown emissions are included for all six turbine families. The issue is the missing underlying support in the released materials: test results, manufacturer documentation or engineering analysis validating those estimates.
TCEQ should require support for emissions per event, event durations and assumptions about when controls become effective. It should also establish how event frequency and emissions during those periods will be tracked and constrained.
What does this mean?
Starting a turbine is different from running it steadily. Pollution controls may provide reduced performance while conditions change. Listing a number for these periods is a starting point; the record needs to show why that number adequately represents the proposed equipment and operation.
What about the independent 311.77-ton estimate?
The independent workbook’s 311.77-ton NOₓ estimate uses generic EPA factors for startup/shutdown. Such factors can help estimate emissions when better equipment-specific information is unavailable, but the selected factors describe high-load operation and need justification for these transient periods. We retain that result as an alternative estimate, not a verified project maximum. The focused 263.98-ton normal-operation calculation does not depend on that substitution.
5. Are particle emissions and pollution controls adequately supported?
The application and independent workbook both put volatile organic compounds and particulate matter below 250 tons per year. Their particle estimates differ, and TCEQ should establish whether the relevant guarantees include particles that form as hot exhaust cools, as well as those already present in the stack.
The application also relies on catalytic controls. TCEQ needs to identify the operating conditions supporting their performance and the testing, monitoring, maintenance and reporting needed to verify it.
Why is this important?
A manufacturer’s supported guarantee can be more useful than a generic factor. The guarantee must cover the proposed equipment and operating range, and the permit must provide a way to check performance. If NOₓ makes the plant major for PSD, other pollutants emitted in significant amounts can also require additional control review even below 250 tons each.
The conclusion
Show the evidence. Reconcile the numbers. Make the limits work.
Our position is that these issues must be resolved before approval under the requested standard permit. TCEQ should identify the operative application, correct or explain the calculations, provide the supporting equipment data and document enforceable limits and compliance methods.
If supported potential emissions reach the applicable major-source threshold, the corresponding permitting route should apply. If they stay below it, the record should explain precisely why and what prevents operation outside that basis.
The full report provides the calculations, assumptions and sources. This update summarizes it for residents. We are requesting that TCEQ evaluate the findings as part of its technical review.
Community action · Tomorrow, Tuesday, October 13
Ask commissioners to demand a public meeting with TCEQ.
The October 13 agenda includes Item E.6, a proposed resolution requesting a TCEQ public meeting about Pacifico’s gas plant. Ask commissioners to adopt it and send it promptly to TCEQ.
Commissioners Courtroom, second floor
804 Pecan Street, Bastrop
Resolution: Item E.6
- Arrive before 9 a.m. Bring a neighbor; attending matters even if you do not speak.
- Complete the public participation form. Mark Item E.6 and “For,” and give it to the County Clerk before that item is discussed.
- Ask for answers grounded in the technical record. Explain why the emissions discrepancies, operating limits and control performance deserve a public discussion before approval.
Comments normally have a three-minute limit, subject to adjustment by the presiding officer. Keep them specific and civil.
A short statement you can personalize
I support Item E.6. Please adopt the resolution and send it promptly to TCEQ. The released application contains unresolved emissions and operating-limit questions. Residents need a public meeting where TCEQ and the applicant explain the calculations, supporting evidence and enforceable protections before approval.
The County can put its request on record. Its vote would not grant or deny the air authorization or guarantee that TCEQ will hold a meeting. A public meeting and a contested-case hearing are different proceedings.
Next week · Tuesday, October 20
Bring your questions. Bring a neighbor.
Join the Lost Pines Watch Town Hall: The Pause, the Permit, and What Happens Next. We will explain the records, discuss the decisions ahead and make room for residents’ questions and concerns. You do not need to know the technical vocabulary to take part.
Lost Pines Pickleball Club
1099 State Hwy 71, Bastrop, TX 78602
Share the event with your friends and invite someone who has not heard about the proposal.
Keep the community informed
Share the findings—and help keep this work going.
Follow Lost Pines Watch on Facebook and Instagram. Share this update, comment on our posts and help a neighbor find the meeting information. Personal, civil comments help show the people behind the numbers.
Help unlock the $12,000 legal-fee match.
A donor has committed $12,000 toward legal fees, contingent on the community raising a matching $12,000. Meeting that goal would put $24,000 toward legal work. If you can contribute, please donate and share the appeal.
Get email alerts for meeting reminders and substantive project updates.
Read the records behind this update.
- Pacifico Air Permit Emissions Analysis, revised October 6, 2026 (PDF)—the full calculations and cited application pages.
- EPA: Basic Information about NO₂.
- October 13 Commissioners Court agenda and proposed public-meeting resolution.
- County meeting dates and location, participation form and speaking rules.
- October 20 town hall details.
Prepared October 12, 2026. Findings concern the released August application; the October 6 report identifies the scope and limitations of the review. Meeting times, location and participation instructions are linked to their sources. The email transmission and fundraising match are confirmed by Lost Pines Watch’s organizer.