{
  "schema_version": "dcd-policy-actions-1",
  "as_of": "2026-09-22",
  "seed_boundary": "This is an initial seed of actions whose primary sources were opened, not a 50-state audit. A state with no row here has not been cleared. Absence from this seed is not a finding that restrictions, incentives, or studies are absent for that state or its local governments. No state is described as open.",
  "texas_reconciliation": "These Texas records are related instruments. None is recorded as superseding another. Together, the approval and permit directives are a temporary approval and permit pause pending an audit. This is not a permanent ban on existing facilities. The 3 August 2026 letter tells the Public Utility Commission and ERCOT to audit data centers advancing through ERCOT interconnection before any additional data centers are approved to move forward. It states no end date. ERCOT's 3 August 2026 market notice postponed Batch Zero classification of large loads past 7 August 2026. ERCOT's 20 August 2026 presentation says energization approvals are paused for data centers and virtual-currency mining facilities of 75 MW or greater until Batch Zero eligibility verification is complete. The 14 September 2026 board update says that pause continues until the verification and audit and the community-impact review are complete. Those materials give 10 December 2026 as a report-filing goal, not as a legal expiration. That energization pause does not, on ERCOT's description, apply to non-data-center large loads or to medium loads. The 21 September 2026 letter tells TCEQ to halt permits sought by data centers until ERCOT completes its review, and it says no other state agency should move regulatory approvals forward until the requested information is acquired. 19 October 2026 is a compliance-update date, not an expiration. The same letter says the governor will seek legislation to eliminate data-center financial incentives. That legislation is not recorded as enacted. The Comptroller was still describing the sales-tax exemption program on 22 September 2026.",
  "coverage_audits": [],
  "actions": [
    {
      "id": "tx-abbott-ercot-approval-pause-20260803",
      "state": "TX",
      "locality": null,
      "jurisdiction_level": "state",
      "action_type": "statewide_permit_or_approval_pause",
      "status": "in_effect",
      "affected_stage": "interconnection",
      "exact_scope": "The letter directs the Public Utility Commission of Texas and ERCOT to conduct a verification and audit of data centers advancing through ERCOT's interconnection process before any additional data centers are approved to move forward. A project that fails that process must be denied connection to the Texas grid as described in the letter. The letter does not order existing operating facilities to shut down, does not state a calendar end date, and is addressed to the ERCOT interconnection process rather than to every electric utility in Texas.",
      "effective_date": "2026-08-03",
      "effective_date_precision": "day",
      "scheduled_expiration_date": null,
      "completion_condition": "The audit must be completed before any additional data centers are approved to move forward. The letter states no calendar expiration.",
      "ended_on": null,
      "last_checked": "2026-09-22",
      "issuing_authority": "Governor of Texas",
      "primary_source_url": "https://gov.texas.gov/uploads/files/press/Thomas_Gleeson_Pablo_Vegas_Data_Centers_Directive_Letter_to_PUCT_ERCOT_August_2026_.pdf",
      "source_document_date": "2026-08-03",
      "source_document_date_precision": "day",
      "short_label": "ERCOT approval pause pending audit",
      "summary": "On 3 August 2026, Governor Greg Abbott directed the Public Utility Commission of Texas and ERCOT to audit data centers advancing through ERCOT interconnection before any additional data centers are approved to move forward, and to deny grid connection to a project that fails that process. The letter also requires information on public financial assistance, grid dependence and on-site generation, water and cooling, community impacts, and ownership. This is a temporary approval pause pending that audit. It is not a permanent ban on existing facilities. The letter does not say that operating data centers must cease operation.",
      "limitations": [
        "This is a governor's letter to two agencies, not a statute enacted by the Legislature.",
        "The letter does not set a completion day. Later ERCOT materials describe report-filing goals; those goals are recorded on the ERCOT implementation record, not as an expiration of this letter.",
        "The operative pause is approval to move forward through ERCOT interconnection and denial of connection for noncompliance. It does not, on its own text, freeze every state environmental permit. That later step is the 21 September 2026 TCEQ letter.",
        "The letter uses 'the Texas grid' while writing to ERCOT. This record does not treat that phrase as a finding about utilities outside the ERCOT interconnection process."
      ],
      "unresolved_questions": [
        "Whether the Public Utility Commission has issued its own order adopting the letter, separate from ERCOT's later notices, was not established from this letter.",
        "The letter does not define the megawatt threshold for 'data centers advancing through ERCOT's interconnection process.' ERCOT's later energization description uses 75 MW and also names virtual-currency mining facilities."
      ],
      "supersedes": null,
      "superseded_by": null,
      "related_action_ids": [
        "tx-ercot-interconnection-pause-20260803",
        "tx-tceq-permit-pause-20260921",
        "tx-twdb-water-reporting-directive-20260914"
      ],
      "supporting_sources": [
        {
          "label": "Governor's 3 August 2026 press release",
          "url": "https://gov.texas.gov/news/post/governor-abbott-directs-comprehensive-data-center-audit",
          "document_date": "2026-08-03",
          "role": "official press release accompanying the letter"
        }
      ]
    },
    {
      "id": "tx-ercot-interconnection-pause-20260803",
      "state": "TX",
      "locality": null,
      "jurisdiction_level": "regional_grid",
      "action_type": "grid_interconnection_pause",
      "status": "in_effect",
      "affected_stage": "interconnection",
      "exact_scope": "ERCOT market notice M-A080326-01 says ERCOT will not classify large loads in the Batch Zero interconnection study by 7 August 2026 and will seek a good-cause exception from the Public Utility Commission. ERCOT's 20 August 2026 presentation says ERCOT paused approvals to energize data centers and virtual-currency mining facilities of 75 MW or greater. That presentation says the pause does not stop energization approvals for non-data-center large loads and does not apply to medium loads. The 14 September 2026 board update says the energization pause for new large-load data centers and virtual-currency mining facilities continues until the verification audit and community-impact review are complete. None of these documents orders existing operating facilities to shut down.",
      "effective_date": "2026-08-03",
      "effective_date_precision": "day",
      "scheduled_expiration_date": null,
      "completion_condition": "ERCOT's September 2026 board update says energization of the described large-load data centers and virtual-currency mining facilities stays paused until the verification audit and community-impact review are complete. A 10 December 2026 filing goal for two reports is not a scheduled expiration.",
      "ended_on": null,
      "last_checked": "2026-09-22",
      "issuing_authority": "Electric Reliability Council of Texas",
      "primary_source_url": "https://www.ercot.com/services/comm/mkt_notices/M-A080326-01",
      "source_document_date": "2026-08-03",
      "source_document_date_precision": "day",
      "short_label": "ERCOT large-load interconnection pause",
      "summary": "On 3 August 2026, ERCOT said it would not issue Batch Zero large-load classifications by 7 August 2026 after receiving the governor's letter, and that it would ask the Public Utility Commission for a good-cause exception. ERCOT's 21 August 2026 notice says the commission granted those timeline exceptions on 20 August 2026. ERCOT's 20 August 2026 presentation says energization approvals are paused for data centers and virtual-currency mining facilities of 75 MW or greater until Batch Zero eligibility verification is complete. Its 14 September 2026 board update says that energization pause continues until the verification and audit and the community-impact review are complete. The 3 August notice alone does not state that energization pause. This is a grid-interconnection pause for the projects ERCOT describes. It is not a permanent ban on existing facilities.",
      "limitations": [
        "The 3 August 2026 market notice delays Batch Zero classification of large loads. It does not itself say that energization approvals are paused. The 20 August 2026 presentation describes that pause until eligibility verification is complete. The 14 September 2026 board update says the pause continues until the verification audit and the community-impact review are complete.",
        "10 December 2026 is the date ERCOT gave for filing an eligibility-verification report and a community-impact review. It is not stored as a legal expiration.",
        "ERCOT's presentation says non-data-center large loads may still receive energization approval and that medium loads are outside the Batch Zero energization pause.",
        "The Public Utility Commission order granting the good-cause exceptions was not opened in this review. ERCOT's 21 August 2026 notice is the source for the statement that the order was issued on 20 August 2026.",
        "This implementation record does not replace the 3 August governor's letter."
      ],
      "unresolved_questions": [
        "The commission order's exact text, including any conditions beyond the three timeline exceptions described by ERCOT, was not read.",
        "ERCOT's 20 August 2026 presentation says 17 large loads had finished other ERCOT processes but had not received energization approval. This record does not identify those projects or say whether they already hold construction permits.",
        "How ERCOT applies the pause outside the 75 MW data-center and virtual-currency category, including projects that would serve themselves with off-site or behind-the-meter generation, is not settled by the 3 August notice."
      ],
      "supersedes": null,
      "superseded_by": null,
      "related_action_ids": [
        "tx-abbott-ercot-approval-pause-20260803",
        "tx-tceq-permit-pause-20260921",
        "tx-twdb-water-reporting-directive-20260914"
      ],
      "supporting_sources": [
        {
          "label": "ERCOT market notice M-A080326-02",
          "url": "https://www.ercot.com/services/comm/mkt_notices/M-A080326-02",
          "document_date": "2026-08-21",
          "role": "notice that the commission granted timeline exceptions on 20 August 2026"
        },
        {
          "label": "ERCOT Batch Zero verification presentation",
          "url": "https://www.ercot.com/files/docs/2026/08/20/Batch-Zero-Verification-and-Audit-PUCT-Presentation.pdf",
          "document_date": "2026-08-20",
          "role": "ERCOT description of the 75 MW energization pause and what it does not cover"
        },
        {
          "label": "ERCOT board Batch Zero update",
          "url": "https://www.ercot.com/files/docs/2026/09/11/14-Batch-Zero-Update.pdf",
          "document_date": "2026-09-14",
          "role": "later ERCOT status, including the December 10 report-filing goal"
        },
        {
          "label": "ERCOT data center impact request for information",
          "url": "https://www.ercot.com/about/legal/data-center-impact-rfi",
          "document_date": null,
          "role": "information request to developers of data centers of 25 MW or more; not itself the pause"
        }
      ]
    },
    {
      "id": "tx-tceq-permit-pause-20260921",
      "state": "TX",
      "locality": null,
      "jurisdiction_level": "state",
      "action_type": "statewide_permit_or_approval_pause",
      "status": "in_effect",
      "affected_stage": "permitting",
      "exact_scope": "The 21 September 2026 letter directs TCEQ to halt all permits sought by data centers and to pause issuance of all permits related to data center projects until ERCOT completes its review. It also says no other state agency shall move forward with regulatory approvals related to data centers until the information sought by the Public Utility Commission, ERCOT, and the Texas Water Development Board is acquired. The letter sets a 19 October 2026 compliance update and does not set an expiration. It does not say existing operating facilities must shut down, and it does not enact a repeal of tax exemptions.",
      "effective_date": "2026-09-21",
      "effective_date_precision": "day",
      "scheduled_expiration_date": null,
      "completion_condition": "TCEQ is directed to pause issuance of permits related to data center projects until ERCOT completes its review. Other state agencies are told not to move regulatory approvals forward until the requested information is acquired. 19 October 2026 is only the date of a required status update.",
      "ended_on": null,
      "last_checked": "2026-09-22",
      "issuing_authority": "Governor of Texas",
      "primary_source_url": "https://gov.texas.gov/uploads/files/press/TCEQ_Data_Center.pdf",
      "source_document_date": "2026-09-21",
      "source_document_date_precision": "day",
      "short_label": "TCEQ data-center permit pause",
      "summary": "On 21 September 2026, Governor Greg Abbott directed the Texas Commission on Environmental Quality to halt permits sought by data centers and to pause issuance of permits related to data center projects until ERCOT completes its review. The letter also says no other state agency should move regulatory approvals for data centers forward until information sought by the Public Utility Commission, ERCOT, and the Texas Water Development Board is acquired. TCEQ must update the governor by 19 October 2026. That date is not an expiration. This is a temporary permit pause pending the audit. It is not a permanent ban on existing facilities. The letter says the governor will seek legislation to eliminate data-center financial incentives; that legislation is not recorded as enacted.",
      "limitations": [
        "The instrument is the governor's letter. This review did not open a separate TCEQ order, permit list, or implementation memo.",
        "The letter does not name which TCEQ programs are covered, whether a pending application that is already administratively complete is included, or whether a permit amendment for an existing facility is included.",
        "19 October 2026 is a compliance-update date. It is not stored as scheduled_expiration_date.",
        "The sentence about eliminating financial incentives is a statement of future legislative intent. The sales-tax exemption program is a separate record and was still described by the Comptroller on the as-of date.",
        "This letter cites the August interconnection audit and the September water-reporting directive. It does not say those earlier directives are withdrawn."
      ],
      "unresolved_questions": [
        "Whether TCEQ has applied the pause to projects outside the ERCOT footprint is not stated. The pause condition is completion of ERCOT's review, while the addressee is a statewide environmental agency.",
        "The press release's quotation says permits wait until the ERCOT and water-board audits are complete. The letter's operative TCEQ sentence says until ERCOT completes its review. Both documents are from 21 September 2026; the letter is the primary text.",
        "No TCEQ docket or public permit report confirming the pause in practice was opened for this record."
      ],
      "supersedes": null,
      "superseded_by": null,
      "related_action_ids": [
        "tx-abbott-ercot-approval-pause-20260803",
        "tx-ercot-interconnection-pause-20260803",
        "tx-twdb-water-reporting-directive-20260914",
        "tx-data-center-sales-tax-exemption"
      ],
      "supporting_sources": [
        {
          "label": "Governor's 21 September 2026 press release",
          "url": "https://gov.texas.gov/news/post/governor-abbott-directs-tceq-to-halt-data-center-permits",
          "document_date": "2026-09-21",
          "role": "official press release accompanying the letter"
        }
      ]
    },
    {
      "id": "tx-twdb-water-reporting-directive-20260914",
      "state": "TX",
      "locality": null,
      "jurisdiction_level": "state",
      "action_type": "reporting_or_resource_use_requirement",
      "status": "in_effect",
      "affected_stage": "reporting",
      "exact_scope": "The 14 September 2026 letter directs the Texas Water Development Board to compel major water users, including data centers, to comply with existing water-use survey duties, to use statutory remedies for noncompliance, and to partner with ERCOT on its data-center audit to seek water-use information. It is an enforcement and coordination directive about reporting. It does not itself pause interconnection or TCEQ permits, and it does not order operating facilities to shut down.",
      "effective_date": "2026-09-14",
      "effective_date_precision": "day",
      "scheduled_expiration_date": null,
      "completion_condition": "The Board must give the governor an initial update within 30 days and continue updating, including when the audit is completed. The letter states no expiration of the reporting duty.",
      "ended_on": null,
      "last_checked": "2026-09-22",
      "issuing_authority": "Governor of Texas",
      "primary_source_url": "https://gov.texas.gov/uploads/files/press/TWDB_Letter.pdf",
      "source_document_date": "2026-09-14",
      "source_document_date_precision": "day",
      "short_label": "Water-use reporting enforcement directive",
      "summary": "On 14 September 2026, Governor Greg Abbott directed the Texas Water Development Board to enforce existing water-use survey obligations against major water users, including data centers, and to partner with ERCOT so the data-center audit collects water-use information. The letter quotes Water Code section 16.012 on the duty to return the survey and on consequences the statute provides. It asks for an initial progress update within 30 days and further updates when the audit is completed. This record does not find that any particular operator failed to report, and it does not adopt the letter's allegation as a fact. The directive is not a construction pause and does not expire on the update date.",
      "limitations": [
        "The reporting duty cited in the letter is attributed to the Texas Water Code. This review did not re-open the code to confirm the current statutory text.",
        "The letter alleges apparent noncompliance by major water users, including data centers. That allegation is the governor's statement, not a DataCenterData finding about any operator.",
        "A 30-day progress update is not an end date for the survey duty. The press office has described a 14 October 2026 update; the letter itself says 'within 30 days' and does not print that calendar day.",
        "This directive does not replace the 3 August interconnection letter or the later TCEQ permit letter."
      ],
      "unresolved_questions": [
        "Which entities were surveyed for calendar year 2025, and which of them are data centers, is not stated in the letter.",
        "Whether the Board has referred any matter to a prosecutor or notified TCEQ was not checked.",
        "The letter tells the Board to partner with ERCOT on water questions. It does not say that a failure to answer ERCOT's request is, by itself, a Water Code offense."
      ],
      "supersedes": null,
      "superseded_by": null,
      "related_action_ids": [
        "tx-abbott-ercot-approval-pause-20260803",
        "tx-ercot-interconnection-pause-20260803",
        "tx-tceq-permit-pause-20260921"
      ],
      "supporting_sources": [
        {
          "label": "Governor's 14 September 2026 press release",
          "url": "https://gov.texas.gov/news/post/governor-abbott-directs-twdb-to-penalize-data-center-reporting-failures",
          "document_date": "2026-09-14",
          "role": "official press release accompanying the letter"
        }
      ]
    },
    {
      "id": "tx-data-center-sales-tax-exemption",
      "state": "TX",
      "locality": null,
      "jurisdiction_level": "state",
      "action_type": "incentive_or_supportive_policy",
      "status": "in_effect",
      "affected_stage": "incentive",
      "exact_scope": "The Comptroller's program page describes a temporary state sales-and-use tax exemption for qualifying purchases at a certified qualifying data center and at a certified qualifying large data center project. The page says the exemption applies to specified equipment and electricity that are necessary and essential to operation, that local sales and use tax remains due in the cases the page describes, and that each certification lasts 10 or 15 years, or 20 years for a large project, measured from that project's certification. The page does not say the program has been repealed. It is not a finding that every data center in Texas receives the exemption.",
      "effective_date": null,
      "effective_date_precision": "not_a_single_date",
      "scheduled_expiration_date": null,
      "completion_condition": "Each certified project has its own exemption period, described on the Comptroller's page as 10 or 15 years, or 20 years for a qualifying large data center project, starting at certification. The program page states no single statewide repeal date.",
      "ended_on": null,
      "last_checked": "2026-09-22",
      "issuing_authority": "Texas Comptroller of Public Accounts",
      "primary_source_url": "https://comptroller.texas.gov/taxes/data-centers",
      "source_document_date": null,
      "source_document_date_precision": "undated",
      "short_label": "Data center sales-tax exemption",
      "summary": "As of 22 September 2026, the Texas Comptroller's public program page still describes certification and a temporary state sales-tax exemption for qualifying data centers and qualifying large data center projects. The exemption is for specified purchases by a qualifying owner, operator, or occupant after certification. It is an explicitly supportive tax policy, separate from the 2026 approval and permit pauses. A governor's letter dated 21 September 2026 says he will seek legislation to eliminate data-center financial incentives. No enacted repeal is recorded here. Individual certificates expire on the schedule the Comptroller states for that certificate; the program itself has no single expiration day on the page reviewed.",
      "limitations": [
        "The primary source is the Comptroller's program page, which displayed no document date. This review did not re-read every subsection of Tax Code sections 151.359 and 151.3595.",
        "Certification is project-specific. Describing the program as in effect does not mean a named facility is certified.",
        "Chapter 313 appraised-value agreements are an exclusion stated on the page, not a second incentive recorded here.",
        "The governor's 21 September 2026 statement that he will seek to eliminate incentives is legislative intent. It is not recorded as enacted legislation, and it does not supersede this program page."
      ],
      "unresolved_questions": [
        "Whether any 2026 bill has been filed to repeal or narrow the exemption was not established. The official bill text was not opened.",
        "The page links to statute sections. Those links were not used as a substitute for reading the enrolled code."
      ],
      "supersedes": null,
      "superseded_by": null,
      "related_action_ids": [
        "tx-tceq-permit-pause-20260921"
      ],
      "supporting_sources": []
    },
    {
      "id": "ny-eo62-dec-permit-hold-20260714",
      "state": "NY",
      "locality": null,
      "jurisdiction_level": "state",
      "action_type": "statewide_permit_or_approval_pause",
      "status": "in_effect",
      "affected_stage": "permitting",
      "exact_scope": "Executive Order 62 directs the Department of Environmental Conservation to hold in abeyance discretionary permit, approval, license, and similar applications for construction or expansion of a covered data center, when the application is pending or filed after the order and DEC had not determined it complete before 14 July 2026. The order's definition covers facilities, or groups of facilities on the same or contiguous sites, that consume or can consume at least 50 megawatts and meet the stated equipment and service characteristics. It excludes facilities primarily used for manufacturing, specified research, education, or medical care. The order says it does not apply to local-government permissions. It does not pause the NYISO interconnection queue and does not order existing facilities to shut down.",
      "effective_date": "2026-07-14",
      "effective_date_precision": "day",
      "scheduled_expiration_date": null,
      "completion_condition": "The DEC hold lasts until the Department of Public Service submits its report of the final Generic Environmental Impact Statement and the associated findings statement. The order text does not set a one-year expiration. A separate instruction tells DEC to deliver a water-withdrawal assessment no later than twelve months after the order; that report deadline is not the end of the permit hold.",
      "ended_on": null,
      "last_checked": "2026-09-22",
      "issuing_authority": "Governor of New York",
      "primary_source_url": "https://www.governor.ny.gov/executive-order/no-62-establishing-temporary-moratorium-data-centers-new-york-while-state-develops",
      "source_document_date": "2026-07-14",
      "source_document_date_precision": "day",
      "short_label": "DEC hold on large data-center permits",
      "summary": "On 14 July 2026, Governor Kathy Hochul issued Executive Order 62. The order's title calls it a temporary moratorium. Its operative permit clause directs the Department of Environmental Conservation to hold specified discretionary applications for construction or expansion of covered data centers until the Department of Public Service submits a final Generic Environmental Impact Statement and findings. Covered facilities are those that consume or can consume at least 50 megawatts and meet the order's other definition, with stated exclusions. Applications DEC had already determined complete are not held. Local permits are outside the order. The order does not give a calendar expiration, and it does not direct existing operating facilities to shut down.",
      "limitations": [
        "The reviewed text is the HTML publication of the order on the governor's website. The linked PDF was not compared word for word with that HTML.",
        "Public descriptions of a one-year pause were not adopted as the legal end date, because the order's hold continues until the final GEIS and findings are submitted.",
        "The order also directs studies, a community-investment framework, and interconnection working groups. Those directions are not recorded as a separate grid-interconnection pause. The order does not say NYISO must stop processing queue requests.",
        "A bill that legislative offices have described as passed by both houses is not recorded here. The official bill page could not be opened on the as-of date, so its status is an unresolved question rather than a second action.",
        "Calling the order a moratorium repeats its title. The legal effect recorded here is the DEC abeyance, not a prohibition on every data center in New York and not a local construction ordinance."
      ],
      "unresolved_questions": [
        "Whether the Department of Public Service has submitted the final GEIS and findings, which would end the hold under the order's own terms, was not confirmed on 22 September 2026.",
        "How many applications DEC has actually held, and whether any were determined complete before 14 July 2026, was not counted.",
        "The status of the separate Responsible Data Center Development Act, including whether it has been signed or vetoed, was not established from an official bill page."
      ],
      "supersedes": null,
      "superseded_by": null,
      "related_action_ids": null,
      "supporting_sources": [
        {
          "label": "Executive Order 62 PDF linked from the order page",
          "url": "https://www.governor.ny.gov/sites/default/files/2026-07/EO_62.pdf",
          "document_date": "2026-07-14",
          "role": "download linked from the reviewed HTML; not separately compared"
        }
      ]
    }
  ],
  "publication": {
    "license": null,
    "reuse_scope": "reference only unless a record is explicitly rights-cleared",
    "rights_manifest": "/data/rights-manifest.json"
  }
}