Tag Archive for: Texas

Texas Continued Data Center Permitting after the Governor’s Pause

On September 21, 2026, Governor Abbott wrote a letter directing the Texas Commission on Environmental Quality (TCEQ) “to halt all permits sought by data centers.” He framed this pause as an attempt to give ERCOT, the Public Utility Commission of Texas and the Texas Water Development Board time to review the impact of data centers on the Texas grid and existing water resources. He also wrote that “no other state agency shall move forward with regulatory approvals related to data centers until this information is acquired.”

However, working closely with Public Citizen, FracTracker reviewed TCEQ’s records and found that the agency continued moving data center projects forward: mailing public notices for major-source air permit applications, advancing applications through review, issuing air emission-limit certifications, and approving construction stormwater coverage. Since September 21, TCEQ has continued reviewing applications and issuing approvals that allow data center development to proceed.

Governor’s order

Amidst an unprecedented national build-out of data centers and related fossil fuel infrastructure, Texas is the country’s largest market for new data center development. The scale and speed of the build-out have few historical precedents, placing immense pressure on regulators, the Texas grid and water resources, and the communities where these projects are proposed. As the Governor stated in his September 21 letter, the pause was intended to ensure “Texans’ natural resources and way of life are protected.” Abbott’s concern about the negative impacts of data center development marks a shift from his earlier wholehearted embrace of development. On November 14, 2025, he celebrated Google’s data center investments in Texas, stating: “Texas is the epicenter of AI development, where companies can pair innovation with expanding energy.”

Over the past several months, Abbott has publicly changed his position. On August 3, 2026, he directed the Public Utility Commission and ERCOT to audit all data centers advancing through ERCOT’s interconnection process, including their projected electricity and water use, on-site generation, tax incentives, ownership and community impacts. On September 14, he directed the Texas Water Development Board to enforce water-use reporting requirements and partner with ERCOT on the audit. On September 21, he issued his directive to TCEQ and said he would work with the Legislature to eliminate financial incentives for data centers.

The Governor’s letter to TCEQ ordered the pause in three ways:

  • TCEQ was directed “to halt all permits sought by data centers.”
  • TCEQ was directed “to pause the issuance of all permits related to data center projects until ERCOT completes its review.”
  • More broadly, “no other state agency shall move forward with regulatory approvals related to data centers until this information is acquired.”

On October 14, responding to FracTracker’s request for clarification, TCEQ stated that the agency “has paused the issuance of all air and water permits and authorizations related to the construction or development of infrastructure directly supporting data centers while ERCOT completes its comprehensive grid and community impact audit.”

When FracTracker asked whether applications could still move through review without a final approval, TCEQ responded: “Companies can submit applications, but their applications will not advance through the review process.”

That response made TCEQ’s stated position clear: a pause on both the review and issuance of data center permits and authorizations. A review of the agency’s own records found something else.

Map of Texas showing TCEQ actions on data center projects between September 21 and October 16, 2026: 7 air emission certifications issued, 11 construction stormwater coverages approved, 14 gas plant or generator applications fast-tracked or assigned to an engineer, and 3 major-source air permit notices mailed after the order. Sites cluster around Dallas–Fort Worth, Austin–San Antonio, Houston, Abilene and West Texas.
Figure 1. TCEQ actions after the September 21 pause. Public-notice mailings, construction stormwater approvals, air emission-limit certifications and applications advancing through review. See the accompanying spreadsheet for dates, permit records and qualifications about data-center connections.

What the records show

Our review of permitting activity found four kinds of TCEQ actions after September 21: public-notice mailings, stormwater authorizations, air emission-limit certifications and applications continuing to advance through review. Taken together, these actions do not signal an agency trying to pause.

Public Citizen found three preliminary-decision notices for major-source air permit applications that TCEQ mailed on September 22, the day after the Governor’s order. The notices concern VoltaGrid’s ABI-1 plant serving Vantage’s data center campus in Shackelford County, Nexus’s self-powered data center in Hubbard, and NRG Prairie Energy Center in Hill County. The public-notice process continued: VoltaGrid’s notice was published September 23 and Nexus’s September 24. Publication starts the 30-day public-comment period. Given the Governor’s order, people could reasonably have assumed that permitting had stopped while deadlines were actually continuing. That could mean people miss their opportunity to comment or request a public meeting or contested case hearing.

FracTracker also found eleven construction stormwater records with approvals after September 21. These include large hyperscale data centers like Caldwell Valley Technology Park in Caldwell County, Crusoe’s Abilene campus and EdgeConneX’s Cedar Creek campus. All three received new coverage. New coverage removes a required regulatory barrier for clearing, grading and excavation. In other words, these authorizations allow data center construction to proceed. They may not be the only approvals a project needs, but without the required stormwater coverage, that work cannot legally begin.

TCEQ told FracTracker that companies could submit applications, but their applications would not advance through review. We found that this was not the case. In our review, FracTracker found 14 applications for gas plants and generators serving data centers or supporting their construction that continued through review after September 21. An example is Edged Dallas’s generator registration. This permit was filed and expedited on October 6, with an engineer assigned one day later and initial review completed by October 9. Instead of a pause on review, TCEQ has moved forward in their review process, in many cases expediting review. While this is not the same as issuing permits, it certainly appears to violate the Governor’s order that “no other state agency shall move forward with regulatory approvals related to data centers” until the PUC, ERCOT and the Texas Water Development Board complete their reviews.

As further evidence of the regulatory process continuing as normal amidst the pause, FracTracker also identified seven emission-limit certifications that TCEQ’s database recorded as “issued” after the order. These company-submitted certifications establish enforceable emissions limits under separate air authorizations. One, for Decennial’s SA01 Data Center in San Antonio, was recorded October 16, two days after TCEQ told FracTracker it had paused authorizations.

What counts as infrastructure supporting a data center?

TCEQ said its pause included infrastructure “directly supporting data centers.” Reading the permits, how the agency interprets that phrase is open to question.

On October 8, TCEQ approved construction stormwater coverage for LCRA’s Misty substation in Caldwell County. LCRA describes the $111.6 million project as serving Bluebonnet Electric Cooperative’s load. Tract, the developer of Caldwell Valley Technology Park, has a facility-design agreement with Bluebonnet for an initial 360 MW in 2028, and a proposed 1,500 MW gas plant associated with Tract lists Misty as its connection point. That points to infrastructure being built to support data centers. Nothing in the stormwater record calls it a data-center project.

LCRA’s financial statements explain that transmission costs are shared across electricity consumers in ERCOT. Infrastructure built to serve data centers can therefore affect other people’s electricity bills. We have not yet established how Misty’s full cost will be divided. FracTracker is reviewing these transmission upgrades as well. For this report, the question is how TCEQ decides which of them fall under the pause.

We see a similar question with Maverick Lodge, a 4,000-bed workforce camp for data-center construction. Haskell County Ventures filed a gas-generation application to power the camp, which TCEQ expedited October 14 and assigned to an engineer October 16. A pause on infrastructure supporting data centers needs to account for the larger set of projects being filed as part of that build-out.

Lack of transparency around data center development

Identifying which permits corresponded to data centers was particularly challenging. Applicants might be separate power companies, contractors or LLCs whose names reveal little about the campuses they serve. At FracTracker, we compared the permits with our database of data-center locations. SMS Horizon EC1, for example, filed for a plant at the same road corner as Poolside’s proposed campus in Pecos County. The LLC also shared a name with an LLC associated with the Poolside data center. The location suggests a connection, but we have not found a document tying the two together.

What we need is a clear public database connecting each campus to its owners, related LLCs, power plants, water infrastructure, permit numbers and review status. Texas could follow the example of Pennsylvania, which has a centralized Data Center Permit Tracker. Residents should be able to see which projects are being proposed and what infrastructure is being built to serve them.

Recommendations

Data-center developments moving through permitting despite the Governor’s order show why Texas needs a statewide moratorium. A moratorium would give Texans more time to study the impacts of this build-out. ERCOT, the PUC and the Texas Water Development Board need time for cumulative-impact studies, regional analyses of proposed data-center clusters and long-term planning. Local communities need more opportunities to participate in decisions about land use and data-center development.

TCEQ needs to comply with its stated pause on reviewing applications and issuing authorizations for data centers and the infrastructure supporting them. That includes expedited review, air certifications and stormwater coverage. It should also extend or reopen the affected comment periods so people have a full opportunity to comment after the pause ends. People who reasonably thought permitting had stopped should not lose their chance to participate.

TCEQ should explain any failures to pause review and permitting. TCEQ’s compliance update to the Governor is due today, October 19. This compliance update should be made available to the public. If it does not address the discrepancies we found, TCEQ should produce an addendum giving a public accounting of how it advanced permitting after September 21 and what it will do to prevent that from continuing.

Records and sources

We checked records through October 16, 2026. Dates and sources are linked in the accompanying spreadsheet.

Additional sources include the Governor’s September 21 letter, TCEQ’s construction general permit and public guidance, TCEQ’s emails to FracTracker, and TCEQ’s permit and public-notice records. This report benefited greatly from the collaboration with Public Citizen, who identified additional air, water and major-source permits that our own search did not find, which we then reviewed and included here.

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Pipeline Incidents Are a Daily Occurrence

Pipeline incidents are more common, more dangerous, and more underreported than you might realize. This articles investigates a critical infrastructure system plagued by daily disasters and raises serious questions about data integrity and public safety. Read on to discover the full extent of the problem.

East Palestine Train Derailment Waste: Community Impacts

As of March 10, 2023, 152,796 tons of liquid waste and 2,980 tons of solid waste have been removed from the site of the train derailment in East Palestine, Ohio, to three injection wells and four hazardous waste disposal sites in Ohio, Michigan, Indiana, and Texas.

Desalination: The Chemical Industry’s Demand for Water in Texas

Desalination facilities proposed by the petrochemical industry in Texas could significantly impact fragile Gulf Coast ecosystems.

Southeastern Texas Petrochemical Industry Needs 318 Billion Gallons of Water, but the US EPA Says Not So Fast

The US EPA is moving to turn off the tap to Texas’ petrochemical operators that are demanding exorbitant water quantities where there are none.

Infrastructure Networks in Texas

This map illustrates infrastructure networks in Texas and explores how these unseen webs connect us and improve lives, but also carry risks and burdens.

Mapping PFAS “Forever Chemicals” in Oil & Gas Operations

FracTracker Alliance released a new map identifying the locations of over 1,200 oil and gas wells using toxic “forever chemicals” in Arkansas, Louisiana, Oklahoma, New Mexico, Texas, and Wyoming. 

Mapping intersectionality: Empowering youth addressing plastics

VIEW MAP & DATA

Overview

A new collaboration between FracTracker Alliance and Algalita is aiming to help middle school and high school students understand the connection between plastics and fracking — and the wide ranging implications for climate change, environmental injustice, and human health.


Most young people today understand that plastics are problematic. But, there is still often a disconnect between the symptom of plastics in our oceans, and the root causes of the problem. Algalita’s mission is to empower a new generation of critical thinkers to shift the broken and unjust systems that are causing the plastic pollution crisis. Algalita’s strategy is creating educational experiences directly with the movement’s diverse leaders, and this new project with FracTracker is a perfect example. 

Specifically, Algalita and FracTracker have been working together to add new lessons to Algalita’s brand-new online, gamified, action platform: Wayfinder Society. Through this program, students can guide their own exploration of the complexities of the plastics issue, and can take action at their own pace and scale, by completing lessons and action-items (called Waymarks) based on difficulty, topic, and type of impact. 

The first of two FracTracker Waymarks outlines the connection between fracking and plastic production. Students explore a map showing the full plastics production process from fracking pads, to pipelines, to ethane crackers, and packaging factories. 

In a second Waymark that builds off of the first, students explore the massive petrochemical buildout on the Gulf Coast and in the Ohio River Valley. The map allows students to analyze the greenhouse gas emissions predicted for this buildout using the data point pop-up boxes. They can also examine the effects of climate change on communities amongst the buildout by viewing the coastal flood zone areas in Texas and Louisiana. Beyond that, students can investigate how facilities are impacting their peers in schools close to massive ethane cracker facilities. Finally, students are introduced to the movement’s #PlasticFreePresident Campaign, giving them a direct action to apply their new knowledge. 

Mapping Fracking’s Link to Plastic Production

This StoryMap was created by FracTracker for Wayfinder Society, a program by Algalita. Learn more at Algalita.org. Place your cursor over the image and scroll down to advance the StoryMap and explore a series of maps charting the fracking-for-plastic system. Click on the icon in the bottom left to view the legend. Scroll to the end of the StoryMap to learn more and access the data sources.

View Full Sized Map | Updated 11/20

 

Algalita is excited about this partnership for so many reasons. For one, GIS is a critical skill for young people to learn. These two Waymarks pose an accessible and non-intimidating introduction to ArcGIS by using simple maps and StoryMaps like the one above. The maps let students get comfortable with GIS concepts and capabilities like layers, data attribute tables, measuring tools, and filters. Allowing students to explore how plastics are produced through a geographical lens provides a unique visual and interactive experience for them. The goal is for students to be able to connect petrochem buildout, with the plastics, climate and justice issues that they are focusing on — often separately. Our aim is that by putting this part of the story in context of real physical space they will more easily make those connections. We hope these lessons spark some students’ interest in mapping, geography, and GIS, providing a new generation of changemakers with GIS in their toolbox. 

On top of that, we are stoked to be building this partnership with FracTracker because the success of our collective movement depends on strong, clear communication and synergies between the nodes of the movement’s network.  The FracTracker Waymarks give our Wayfinders direct access to real-time data, visualizations, and expert insights that they can then use to level-up their actions and stories around their activism. And, they connect the dots not just for students, but also for educators and movement partners like us at Algalita — we are all for this powerful lever for change!

Check out Wayfinder Society here. Access the FracTracker Waymarks here and here — but you’ll need to be logged in. If you’re a student, get started by creating a profile, and then start earning Cairns (points)! If you’re an educator, parent or mentor, and interested in exploring the site, email us here for the guest login. 

By Anika Ballent, Education Director, Algalita

Algalita empowers a new generation of critical thinkers who will shift the broken and unjust systems that are causing the plastic pollution crisis.  We do this by offering educational experiences created directly with the movement’s diverse leaders.

Anika has been working in the movement against plastic pollution for ten years, studying microplastics in benthic and freshwater environments. She brings together her science background and creativity to educate young changemakers through hands-on experiences in schools, Algalita’s International Youth Summit, and online programs.


References & Where to Learn More

Algalita.org

Data Sources:

ATEX Pipeline: EIA

Railroad: Selection from ArcGIS online

Process information: Houston Chronicle

Falcon Pipeline: Shell/AECOM and FracTracker Alliance

Mariner East 2 Pipeline: PA DEP

Greenhouse gas emission increases: Environmental Integrity Project. (2020, November 30). Emission Increase Database. Retrieved from https://environmentalintegrity.org/oil-gas-infrastructure-emissions.

All other data points were mapped by FracTracker Alliance referencing various online sources. While this map is based on actual infrastructure, it is intended as a model of the fracking-for-plastic lifecycle and certain steps may vary in real life.

Topics in This Article

Petrochemicals & Plastics


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Channels of Life: The Gulf Coast Buildout in Texas

It’s been a little over a year since I visited the Texas Gulf Coast to document the oil, gas, and petrochemical landscape with our partners at LightHawk and Scott Humphries, an amazing pilot and Houston native.

Much has happened since then – in regard to and because of – the Gulf Coast’s petrochemical industry.

The fossil fuel landscape along the Gulf Coast is broad, and its impact is heavy.

The area has seen a massive build out over the last five years. New plastics and steel manufacturing facilities and pipelines from the Permian Basin that transport crude to ever-expanding tank farms and marine terminals – all with the blessings of local economic development groups and local government, despite known present and potential hazards.

As these developments continue, communities and workers pay the price. An incident in early December, 2020 left workers injured after a condensate fire at a Citgo tank farm in Corpus Christi. Before that, a pipeline explosion on August 20th in the Corpus Christi Ship Channel resulted in four deaths, with only two of those bodies recovered.

Channels of Life, below, is a short video looking at what is already on the ground, and what is on the horizon. Whether you are pleasure-boating in the channels or driving down the highway, you only see the edge of industrial sprawl that already exists. The depth of the incursion is not visible from the ground. Further down in an interactive Story Map, we give you a rare look from above, while pinpointing various incidents and facilities of concern. Partnering with LightHawk, we flew from Port Aransas, up the La Quinta Channel to the Nueces Delta, and ending at Refinery Row, giving you a bird’s-eye view of the sprawling fossil fuel landscape.

How much more industrial saturation can the Coastal Bend’s public health and ecosystem withstand before it is all sacrificed?

Is it destined to become a sacrifice zone for increasing corporate wealth and prestige?

 

 

Channels of Life

In many parts of Texas – as well as in Louisiana and New Mexico – oil, gas, and petrochemical facilities abut schools, backyards, and playgrounds. The Gulf Coast contains 95% of the country’s ethylene capacity and roughly half of the country’s petroleum refining and natural gas processing capacity. This development has propelled a new wave of petroleum and petrochemical infrastructure in recent years. There are 129 planned or recently completed petrochemical facilities in TX and LA alone.

This buildout has enormous consequences for the country’s greenhouse gas emissions, including intensifying climate change; increasing production of (often radioactive) waste and the need for its disposal; and discharging dangerous pollution into frontline communities where health has already been compromised by industry activities.

As the sacrifice builds and the losses mount, economic development corporations advertise the area as prime real estate for more facilities and infrastructure – even as markets steadily move away from fossil fuels. Exports are a tenuous lifeline for an industry drowning in an oversupply of oil and gas, but advocates like the Port of Corpus Christi Authority insist on proposing, financing, and constructing new crude oil and liquefied natural gas (LNG) export terminals along the Gulf Coast, including the BlueWater and GulfLink terminals.

Even with access to global markets, the outlook for this Gulf Coast petrochemical expansion doesn’t look great. Countries that planned to import the US’ fossil fuels are withdrawing interest, citing climate concerns. Major projects are being abandoned, like the petrochemical facility Project Falcon that SABIC had planned to build near Aransas Pass. Frontline communities that have suffered devastating health impacts from the industry for too long are calling out environmental racism and causing major delays for new facilities.

These Texan sites are further captured in the Story Map below, as are the footprints of countless other existing and proposed petrochemical infrastructure sites, from the frac sand mines south of San Antonio down into Corpus Christi Bay, the mushrooming industry along the La Quinta Channel, up the Gulf Coast to Freeport, and finally along the always hectic Houston Ship Channel that empties out into Galveston Bay.

Group shot in front of airplane

Left to Right: Corpus Christi native and Coastal Alliance to Protect Our Environment (CAPE) member Dewey Magee, FracTracker Alliance’s Ted Auch, and LightHawk pilot Scott Humphries stand outside Scott’s Beechcraft Bonanza A-36 at McCampbell-Porter Airport in Aransas Pass, TX, November 11th, 2019. Photo by Errol Summerlin

 

Skyline landscape shot of Corpus Christi, TX

The View of Corpus Christi’s Petrochemical Corridor along La Quinta Channel and Tule Lake Shipping Channel from 200’ above McCampbell-Porter Airport in Aransas Pass, TX, November 11th, 2019. Photo by Ted Auch, FracTracker Alliance

 

I reached out to pilot and native Houstonian Scott Humphries for his thoughts on what he expected and what he gleaned from our flight. He wrote the following:

Question #1: What about our proposed flight interested you as a Texan and/or Houstonian – or just more generally – what interested you about this mission?

I’ve always tried to be environmentally conscious, and always try to have, “think globally, act locally” rummaging around in my head, but this mission (and affiliating with LightHawk generally) presented an opportunity for me to try to (hopefully) have a little more impact than just personally recycling, outlawing Styrofoam cups at our office, etc. Separately, as a longtime Houstonian, I’ve always been proud to live and work in what many refer to as the “Energy Capital of the World.” This mission seemed a useful way to do some small part to help make sure that title continues to be held responsibly.

Question #2: After conducting the flights, or as they were happening, did you learn anything, or have any thoughts that surprised you or realizations about anything particular?

I have flown along the Gulf Coast (including to/from Houston/Corpus Christi) many, many times, and if you’d asked me before this mission, I would have said, ‘Sure, there’s a decent amount of industry along that part of the coast.’ What surprised me while we were flying was two things: (1) there’s not just a decent amount of industry along that part of the coast; rather, along that route, even flying low, you’re rarely – if ever – out of sight of a significant facility of some kind, and (2) the size of the facilities – in other circumstances I’d have been flying much higher and wouldn’t get a good sense of the size of the pads.  Flying as we were at just over 1000′, it was striking how massive the various plants were, both in Corpus Christi Bay and along the coast.

Another perspective on this flight and the area we flew over comes from Kevin Sims, Aransas Bay Birding Charters Operator whose Whooping Crane and Pink Spoonbill photos we feature in the story map below. Kevin has been plying the waters in and around Aransas Wildlife Refuge since 1972, and when I contacted him about using some of his photos, he told me the following:

“We need the desalination plants, but the planned discharge points are going to cripple our ecology and the business that rely on it for tourism. They could’ve discharged offshore, but instead they are discharging into the bay, and if it gets too salty the crab populations will plummet, and everything around here depends on crabs and shrimp. If we have a constant influx of brine it could really cripple us. I went to a fantastic meeting from Texas A&M, and their science told them that if red fish larvae migrated into the [Aransas Pass] shipping channel and hit a wall of salty water, they wouldn’t go further, and their population would crash. But despite these facts, they’ve chosen to discharge into the La Quinta Channel, and that is bad news! They were having fairly regular meetings on all of these proposals prior to COVID, but once COVID hit, they went all remote, and less people knew when the meetings were, and the meeting details weren’t widely disseminated … So, the next thing we knew, everything was passed, and they’re gonna [sic] go ahead and do [all of] it. 

My perspective comes from a lifetime of fishing and observing the Whooping Crane, and watching them progress from 157 eighteen years ago, to 507 at the present time. Well, I feel this will threaten an endangered species that they’ve been trying to bring back from the brink of extinction since the 1940s. I can remember my dad showing me the cranes in the mid-70s, and there were only 52-55. All of the projects you are mapping have the potential to decimate all the progress made, not to mention money spent on Whooping Crane recovery. From my perspective, it’s a catch-22, ‘cause [sic] the big cities take the water out of the river, and they don’t have the inflows into the bays that they did in the past. We also don’t have the rains that we used to have. The desalination plants would relieve some of that pressure if they would just put that brine offshore. The other species of concern to my industry is the Pink Spoonbills, but the Whooping Crane is the main draw.”

Channels of Life: The Gulf Coast Buildout in TX

A Story Map

This Story Map illustrates the impacts of oil and gas infrastructure from San Antonio down to Corpus Christi, and then up the Gulf Coast to Houston.

The map displays aerial photographs of infrastructure, from frac sand mines and refineries, to chemical plants and offshore drill rig construction sites. This map includes CO2 emissions from oil and gas infrastructure from 2010 – 2018 (weighted by total CO2 during this period in orange), and/or oil refineries and their myriad products (weighted by capacity in black [barrels/day oil equivalents]).

The Story Map also presents detailed information and locations for proposed petrochemical infrastructure in the Corpus Christi Bay region, courtesy of Errol Summerlin and our partners at Coastal Alliance to Protect Our Environment (CAPE). These proposals include dredging projects needed to accommodate more traffic from larger tanker ships, as well as desalination facilities that would collectively intake 758 million gallons of Corpus Christi Bay water each day, and discharge 507 million gallons of brine per day, with an average of 95 and 64 million gallons of desalinated water produced daily, respectively.

The perforated yellow line is the flight path we took with our LightHawk partners. When the viewer scrolls into any given region, they will see SkyTruth incident alerts within five miles of our flight path. The two examples cited at the beginning of this article are just a couple of the nearly 760 such incidents in just the Corpus Christi Shipping Channel since 2011, according to data provided by SkyTruth.

The most recent data in this map is Whooping Crane locations and number counts in TX as of November 2020, courtesy of The Cornell Lab of Ornithology’s eBird data portal. This data speaks to the concerns of Mr. Sims and many of his colleagues who rely on the Whooping Crane’s attraction to birders internationally, and it also highlights that the projects photographed and in the works across Corpus Christi Bay will not just negatively affect the human communities, but will have far reaching impacts on the ecosystems of the western Gulf, and the industries that have relied on these ecosystems for all manner of ecosystems services.

We recommend viewing this map in full screen

 

Looking forward

Decades of oil and gas development have created a dependency on extractive industries, which has in turn hindered community health and stability.

The Port of Corpus Christi’s controversial dock expansion and Harbor Bridge replacement project at the southern end of Refinery Row has taken over community land and eclipsed their fight to protect their neighborhoods and their public health. Even after an environmental review, the preferred route cuts through these neighborhoods that are surrounded by industry, interstates, and waste treatment facilities – isolated from other residences, and subjected to heavy pollution, noise, and constant hazard.

But with interest and investments declining in the fossil fuel industry and overproduction keeping prices low, the future of the Gulf Coast, its people, environment, and industrial landscape is uncertain – but resistance to extractive industry is strong.

Several activists and environmental coalitions are fighting this project and the industrial onslaught for the health of their communities. For more information on how to support their vision, visit our friends at Coastal Alliance to Protect our Environment (CAPE) and Texas Environmental Justice Advocacy Services (TEJAS).

 

Thank You

This video, Story Map and article were produced with much gratitude and appreciation for our partners at LightHawk, as well as the support and resources of Scott Humphries, Kevin Sims, and Errol Summerlin.


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Foreign Trade Zone Sign Feature

Industry Targets Peaceful Protest via “Critical Infrastructure” Legislation

By Ted Auch, PhD, Great Lakes Program Coordinator and Shannon Smith, Manager of Communications & Development

The oil and gas industry continues to use rhetoric focusing on national security and energy independence in order to advocate for legislation to criminalize climate activists. Backlash against protestors and environmental stewards has only increased since the onset of COVID-19, suggesting that industry proponents are exploiting this public health crisis to further their own dangerous and controversial policies.[1]

Industry actors contributing to the wave of anti-protest bills include American Petroleum Institute (API), IHS Markit, The American Fuel & Petrochemical Manufacturers (AFPM), and most effectively, the American Legislative Exchange Council (ALEC), by way of its primary financial backer, Koch Industries (Fang, 2014, Shelor, 2017).

ALEC is the source of the model legislation “Critical Infrastructure Protection Act” of 2017, intended to make it a felony to “impede,” “inhibit,” “impair,” or “interrupt” critical infrastructure operation and/or construction. Close approximations – if not exact replicas – of this legislative template have been passed in 11 hydrocarbon rich and/or pathway states, and 8 more are being debated in 4 additional states.

The “critical infrastructure” designation in ALEC’s “Critical Infrastructure Protection Act” is extremely broad, including over 70 pieces of infrastructure, from wastewater treatment and well pads, to ports and pipelines. However, along with the 259 Foreign Trade Zones (FTZ) (Figures 1 and 4) supervised by US Customs and Border Protection (CBP), security is of such importance because over 50% of this infrastructure is related to oil and gas. According to our analysis, there are more than 8,000 unique pieces of infrastructure that fall under this designation, with over 10% in the Marcellus/Utica states of Ohio, West Virginia, and Pennsylvania. See Figure 1 for the number of FTZ per state.

Regarding FTZ, the US Department of Homeland Security doesn’t attempt to hide their genuine nature, boldly proclaiming them “… the United States’ version of what are known internationally as free-trade zones … to serve adequately ‘the public interest’.” If there remains any confusion as to who these zones are geared toward, the US Department of Commerce’s International Administration (ITA) makes the link between FTZ and the fossil fuel industry explicit in its FTZ FAQ page, stating “The largest industry currently using zone procedures is the petroleum refining industry.” (Figure 2)

 

Figure 1. Number of Foreign-Trade Zones (FTZ) by state as of June 2020.

Figure 2. Foreign-Trade Zone (FTZ) Board of Actions in Zones 87 in Lake Charles, LA, 115-117 in and around Port Arthur, TX, and 122 in Corpus Christi, TX. (click on the images to enlarge)

 

Foreign-Trade Zone (FTZ) Board of Actions in Zone 87 in Lake Charles, Louisiana

Foreign-Trade Zone (FTZ) Board of Actions in Zone 87 in Lake Charles, Louisiana

Foreign-Trade Zone (FTZ) Board of Actions in Zones 115-117 in and around Port Arthur, Texas

Foreign-Trade Zone (FTZ) Board of Actions in Zones 115-117 in and around Port Arthur, Texas

Foreign-Trade Zone (FTZ) Board of Actions in Zone 122 in Corpus Christi, Texas

Foreign-Trade Zone (FTZ) Board of Actions in Zone 122 in Corpus Christi, Texas

 

Much of the oil, gas, and petrochemical industries’ efforts stem from the mass resistance to the Dakota Access Pipeline (DAPL). Native American tribes and environmental groups spent months protesting the environmentally risky $3.78 billion dollar project, which began production in June 2017, after Donald Trump signed an executive order to expedite construction during his first week in office. The Standing Rock Sioux tribe also sued the US government in a campaign effort to protect their tribal lands. The world watched as Energy Transfer Partners (ETP), the company building the pipeline, destroyed Native artifacts and sacred sites, and as police deployed tear gas and sprayed protesters with water in temperatures below freezing.

ETP’s bottom line and reputation were damaged during the fight against DAPL. Besides increasingly militarized law enforcement, the oil and gas industry has retaliated by criminalizing similar types of protests against fossil fuel infrastructure. However, the tireless work of Native Americans and environmental advocates has resulted in a recent victory in March 2020, when a federal judge ordered a halt to the pipeline’s production and an extensive new environmental review of DAPL.

Just days ago, on July 6, 2020, a federal judge ruled that DAPL must shut down until further environmental review can assess potential hazards to the landscape and water quality of the Tribe’s water source. This is certainly a victory for the Standing Rock Sioux Tribe and other environmental defenders, but the decision is subject to appeal.

Since the DAPL conflict began, the industry has been hastily coordinating state-level legislation in anticipation of resistance to other notable national gas transmission pipelines, more locally concerning projects like Class II Oil and Gas Waste Injection Wells, and miles of gas gathering pipelines that transport increasing streams of waste – as well as oil and gas – to coastal processing sites.

 

The following “critical infrastructure” bills have already been enacted:

STATE BILL TITLE DATE PASSED
West Virginia HB 4615 NEW PENALTIES FOR PROTESTS NEAR GAS AND OIL PIPELINES 3/25/20
South Dakota SB 151 NEW PENALTIES FOR PROTESTS NEAR PIPELINES AND OTHER INFRASTRUCTURE 3/18/20
Kentucky HB 44 NEW PENALTIES FOR PROTESTS NEAR PIPELINES AND OTHER INFRASTRUCTURE 3/16/20
Wisconsin AB 426 NEW PENALTIES FOR PROTESTS NEAR GAS AND OIL PIPELINES 11/21/19
Missouri HB 355 NEW PENALTIES FOR PROTESTS NEAR GAS AND OIL PIPELINES 7/11/19
Texas HB 3557 NEW CRIMINAL AND CIVIL PENALTIES FOR PROTESTS AROUND CRITICAL INFRASTRUCTURE 6/14/19
Tennessee SB 264 NEW PENALTIES FOR PROTESTS NEAR GAS AND OIL PIPELINES 5/10/19
Indiana SB 471 NEW PENALTIES FOR PROTESTS NEAR CRITICAL INFRASTRUCTURE 5/6/19
North Dakota HB 2044 HEIGHTENED PENALTIES FOR PROTESTS NEAR CRITICAL INFRASTRUCTURE 4/10/19
Louisiana HB 727 HEIGHTENED PENALTIES FOR PROTESTING NEAR A PIPELINE 5/30/18
Oklahoma HB 1123 NEW PENALTIES FOR PROTESTS NEAR CRITICAL INFRASTRUCTURE 5/3/17

 

There are an additional eight bills proposed and under consideration in these six states:

STATE PENDING TITLE DATE PROPOSED
Louisiana HB 197 NEW PENALTIES FOR PROTESTS NEAR CRITICAL INFRASTRUCTURE 2/24/20
Minnesota HF 3668 NEW PENALTIES FOR PROTESTS NEAR GAS AND OIL PIPELINES 2/24/20
Mississippi HB 1243 NEW PENALTIES FOR PROTESTS NEAR CRITICAL INFRASTRUCTURE 2/19/20
Alabama SB 45 NEW PENALTIES FOR PROTESTS NEAR GAS AND OIL PIPELINES 2/4/20
Minnesota HF 2966 NEW PENALTIES FOR PROTESTS NEAR OIL AND GAS PIPELINES 1/31/20
Minnesota SF 2011 NEW PENALTIES FOR PROTESTS NEAR GAS AND OIL PIPELINES 3/4/19
Ohio SB 33 NEW PENALTIES FOR PROTESTS NEAR CRITICAL INFRASTRUCTURE 2/12/19
Illinois HB 1633 NEW PENALTIES FOR PROTESTS NEAR CRITICAL INFRASTRUCTURE 1/31/19

 

Desperate Backlash Against Peaceful Protest

Activists and organizations like the American Civil Liberties Union (ACLU) are framing their opposition to such legislation as an attempt to stave off the worst Orwellian instincts of our elected officials, whether they are in Columbus or Mar-a-Lago. On the other hand, industry and prosecutors are framing these protests as terroristic acts that threaten national security, which is why sentencing comes with a felony conviction and up to ten years in prison. The view of the FBI’s deputy assistant director and top official in charge of domestic terrorism John Lewis is that, “In recent years, the Animal Liberation Front and the Earth Liberation Front have become the most active, criminal extremist elements in the United States … the FBI’s investigation of animal rights extremists and ecoterrorism matters is our highest domestic terrorism investigative priority.”

It shocked many when last week, two protesters in the petrochemical-laden “Cancer Alley” region of Louisiana were arrested and charged under the state’s felony “terrorist” law. Their crime? Placing boxes of nurdles – plastic pellets that are the building blocks of many single-use plastic products – on the doorsteps of fossil fuel lobbyists’ homes. To make matters more ridiculous, the nurdles were illegally dumped by the petrochemical company Formosa Plastics.[2] This is outrageous indeed, but is the sort of legally-sanctioned oppression that fossil fuel industry lobbyists have been successfully advocating for years.

American Fuel & Petrochemical Manufacturers (AFPM) stated in a letter of support for ALEC’s legislative efforts:

“In recent years, there has been a growing and disturbing trend of individuals and organizations attempting to disrupt the operation of critical infrastructure in the energy, manufacturing, telecommunications, and transportation industries. Energy infrastructure is often targeted by environmental activists to raise awareness of climate change and other perceived environmental challenges. These activities, however, expose individuals, communities, and the environment to unacceptable levels of risk, and can cause millions of dollars in damage … As the private sector continues to expand and maintain the infrastructure necessary to safely and reliably deliver energy and other services to hundreds of millions of Americans, policymakers should continue to consider how they can help discourage acts of sabotage … Finally, it will also hold organizations both criminally and vicariously liable for conspiring with individuals who willfully trespass or damage critical infrastructure sites.”

Those organizations deemed ‘criminally and vicariously liable’ would in some states face fines an order of magnitude greater than the actual individual, which would cripple margin-thin environmental groups around the country, and could amount to $100,000 to $1,000,000. The AFPM’s senior vice president for federal and regulatory affairs Derrick Morgan referred to these vicarious organizations as “inspiring … organizations who have ill intent, want to encourage folks to damage property and endanger lives …”

Oklahoma Oil & Gas Association (OKOGA) wrote in a fear-mongering letter to Oklahoma Governor Mary Fallin that such legislation was necessary to “protect all Oklahomans from risk of losing efficient and affordable access to critical services needed to power our daily lives.”

One of the most disturbing aspects of this legislation is that it could, according to the testimony and additional concerns of ACLU of Ohio’s Chief Lobbyist Gary Daniels, equate “‘impeding’ and ‘inhibiting’ the ‘operations’ of a critical infrastructure site” with acts as innocuous as Letters to the Editor, labor strikes or protests, attending and submitting testimony at hearings, or simply voicing your concern or objections to the validity of industry claims and its proposals with emails, faxes, phone calls, or a peaceful protest outside critical infrastructure that raises the concern of site security. Mr. Daniels noted in his additional written testimony that the latter, “may prove inconvenient to the site’s staff, under SB 250 they would be an F3 [Third Degree Felony], and that is without someone even stepping foot on or near the property, as physical presence is not required to be guilty of criminal mischief, as found in/defined in Sec. 2907.07(A)(7) of the bill.”

RISE St. James

Figure 3. A rally held by the Louisiana-based nonprofit RISE St. James.

This connection, when enshrined into law, will have a chilling effect on freedom of speech and assembly, and will stop protests or thoughtful lines of questioning before they even start. As the Ohio Valley Environmental Coalition (OVEC) put it in their request for residents to ask the governor to veto the now-enacted HB 4615, such a bill is unnecessary, duplicative, deceitful, un-American, unconstitutional, and “will further crowd our jails and prisons.”

To combat such industry-friendly legislation that erodes local government control in Ohio, lawmakers like State Senator Nikki Antonio are introducing resolutions like SR 221, which would, “abolish corporate personhood and money-as-speech doctrine” made law by the Supreme Court of the United States’ rulings in Citizens United v. FEC and Buckley v. Valeo. After all, the overarching impact of ALEC’s efforts and those described below furthers privatized, short-term profit and socialized, long-term costs, and amplifies the incredibly corrosive Citizen’s United decision a little over a decade ago.

 

Further Criminalization of Protest, Protections for Law Enforcement

Simultaneously, there is an effort to criminalize protest activities through “riot boosting acts,” increased civil liability and decreased police liability, trespassing penalties, and new sanctions for protestors who conceal their identities (by wearing a face mask, for example).

 

The following bills have already been enacted:

STATE BILL TITLE DATE PASSED
South Dakota SB 189 EXPANDED CIVIL LIABILITY FOR PROTESTERS AND PROTEST FUNDERS 3/27/19
West Virginia HB 4618 ELIMINATING POLICE LIABILITY FOR DEATHS WHILE DISPERSING RIOTS AND UNLAWFUL ASSEMBLIES 3/10/18
North Dakota HB 1426 HEIGHTENED PENALTIES FOR RIOT OFFENCES 2/23/17
North Dakota HB 1293 EXPANDED SCOPE OF CRIMINAL TRESPASS 2/23/17
North Dakota HB 1304 NEW PENALTIES FOR PROTESTERS WHO CONCEAL THEIR IDENTITY 2/23/17

 

In addition, the following bills have been proposed and are under consideration:

STATE PENDING TITLE DATE PROPOSED
Rhode Island H 7543 NEW PENALTIES FOR PROTESTERS WHO CONCEAL THEIR IDENTITY 2/12/20
Oregon HB 4126 HARSH PENALTIES FOR PROTESTERS WHO CONCEAL THEIR IDENTITY 1/28/20
Tennessee SB 1750 NEW PENALTIES FOR PROTESTERS WHO CONCEAL THEIR IDENTITY 1/21/20
Ohio HB 362 NEW PENALTIES FOR PROTESTERS WHO CONCEAL THEIR IDENTITY 10/8/19
Pennsylvania SB 887 NEW PENALTIES FOR PROTESTS NEAR “CRITICAL INFRASTRUCTURE” 10/7/19
Massachusetts HB 1588 PROHIBITION ON MASKED DEMONSTRATIONS 1/17/19

 

All the while, the Bundy clan of Utah pillage – and at times – hold our public lands hostage, and white male Michiganders enter the state capital in Lansing armed for Armageddon, because they feel that COVID-19 is a hoax. We imagine that it isn’t these types of folks that West Virginia State Representatives John Shott and Roger Hanshaw had in mind when they wrote and eventually successfully passed HB 4618, which eliminated police liability for deaths while dispersing riots and unlawful assemblies.

Contrarily, South Dakota’s SB 189, or “Riot Boosting Act,” was blocked by the likes of US District Judge Lawrence L. Piersol, who wrote:

“Imagine that if these riot boosting statutes were applied to the protests that took place in Birmingham, Alabama, what might be the result? … Dr. King and the Southern Christian Leadership Conference could have been liable under an identical riot boosting law.”

 

 

Dangerous Work

FracTracker collaborated with Crude Accountability on a report documenting increasing reprisals against environmental activists in the US and Eurasia. Read the Report.

 

A Wave of Anti-Protest Laws in the COVID-19 Era

Despite Judge Piersol’s ruling, South Dakota (SB 151) joined Kentucky (HB 44) and West Virginia (HB 4615) in passing some form of ALEC’s bill since the COVID-19 epidemic took hold of the US. This is classic disaster capitalism. As former Barack Obama Chief of Staff Rahm Emanuel once said, “You never want a serious crisis to go to waste, and what I mean by that is it’s an opportunity to do things you think you could not do before.”

Foreign-Trade Zone Sign

Figure 4. Photo of US Treasury Department signage outlining the warning associated with BP’s Whiting, IN, oil refinery designated a Foreign Trade Zone (FTZ). Photo by Ted Auch July 15th, 2015

In all fairness to Mr. Emanuel, he was referring to the Obama administration’s support for the post-2008 bipartisan Wall Street bailout. However, it is critical that we acknowledge the push for critical infrastructure legislation has been most assuredly bipartisan, with Democratic Governors in Kentucky, Louisiana, and Wisconsin signing into law their versions on March 16th of this year, in May of 2018, and in November of 2019, respectively.

According to the International Center for Not-for-Profit Law, 11 states have passed some version of ALEC’s bill, with the first uncoincidentally being a series of three bills signed in February of 2017 by North Dakota Governor Burgum, targeting “Heightened Penalties for Riot Offences” (HB 1426), “Expanded Scope of Criminal Trespass” (HB 1293), and “New Penalties for Protestors Who Conceal Their Identity” (HB 1304), with at least one member of ALEC’s stable of elected officials, Rep. Kim Koppelman, proudly displaying his affiliation in his biography on the North Dakota Legislative Branch’s website. Mr. Koppelman, along with Rep. Todd Porter out of Mandan, also cosponsored two of these bills.

Related Legislation in Need of Immediate Attention

In Columbus, Ohio, there are several pieces of legislation being pushed in concert with ALEC-led efforts. These include the recently submitted HB 362, that would “create the crime of masked intimidation.” Phil Plummer and George F. Lang sponsor the bill, with the latter being the same official who introduced HB 625, a decidedly anti-local control bill that would preempt communities from banning plastic bags. Most of the general public and some of the country’s largest supermarket chains have identified plastic bag bans as a logical next step as they wrestle with their role in the now universally understood crimes plastics have foisted on our oceans and shores. As Cleveland Scene’s Sam Allard wrote, “bill mills” and their willing collaborators in states like Ohio cause such geographies to march “boldly, with sigils flying in the opposite direction” of progress, and a more renewable and diversified energy future.

With respect to Plummer and Lang’s HB 362, two things must be pointed out:

1) It is eerily similar to North Dakota’s HB 1304 that created new penalties for protestors who conceal their identity, and

2) The North Dakota bill was conveniently signed into law by Governor Burgum on February 23rd, 2017, who had set the day prior as the “deadline for the remaining [DAPL] protesters to leave an encampment on federal land near the area of the pipeline company’s construction site.”

So, when elected officials as far away as Columbus copy and paste legislation passed in the aftermath of the DAPL resistance efforts, it is clear the message they are conveying, and the audience(s) they are trying to intimidate.

Plummer and Lang’s HB 362 would add a section to the state’s “Offenses Against the Public Peace,” Chapter 2917, that would in part read:

No person shall wear a mask or disguise in order to purposely do any of the following:

(A) Obstruct the execution of the law;

(B) Intimidate, hinder, or interrupt a person in the performance of the person’s legal duty; or

(C) Prevent a person from exercising the rights granted to them by the Constitution or the laws of this state.

 

Whoever violates this proposed section is guilty of masked intimidation. Masked intimidation is a first degree misdemeanor. It was critical for the DAPL protestors to protect their faces during tear gas and pepper spray barrages, from county sheriffs and private security contractors alike.

At the present moment, masks are one of the few things standing between COVID-19 and even more death. Given these realities, it is stunning that our elected officials have the time and/or interest in pushing bills such as HB 362 under the thin veil of law and order.

But judging by what one West Virginia resident and former oil and gas industry draftsman,[3] wrote to us recently, elected officials do not really have much to lose, given how little most people think of them:

“Honestly, it doesn’t seem to matter what we do. The only success most of us have had is in possibly slowing the process down and adding to the cost that the companies incur. But then again, the increase in costs probably just gets passed down to the consumers. One of the biggest drawbacks in my County is that most, if not all, of the elected officials are pro drilling. Many of them have profited from it.”

The oil, gas, and petrochemical industries are revealing their weakness by scrambling to pass repressive legislation to counteract activists. But social movements around the world are determined to address interrelated social and environmental issues before climate chaos renders our planet unlivable, particularly for those at the bottom of the socioeconomic ladder. We hope that by shining a light on these bills, more people will become outraged enough to join the fight against antidemocratic legislation.

This is Part I of a two-part series on concerning legislation related to the oil, gas, and petrochemical industries. Part II focuses on bills that would weaken environmental regulations in Ohio, Michigan, and South Dakota.

By Ted Auch, PhD, Great Lakes Program Coordinator and Shannon Smith, Manager of Communications & Development

[1] See Naomi Klein’s concept of the Shock Doctrine for similar trends.

[2] The community-based environmental organization RISE St. James has been working tirelessly to prevent Formosa Plastics from building one of the largest petrochemical complexes in the US in their Parish. Sharon Lavigne is a leading member of RISE St. James, and is an honored recipient of the 2019 Community Sentinel Award for Environmental Stewardship. Read more on Sharon’s work with RISE St. James here.

[3] This individual lives in Central West Virginia, and formerly monitored Oil & Gas company assets in primarily WV, PA, NY, VA, MD & OH, as well as the Gulf Coast. Towards the end of this individual’s career, they provided mapping support for the smart pigging program, call before you dig, and the pipeline integrity program.

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