Public Citizen Comments to the Texas House Committee on Natural Resources Regarding Data Center Water Use
To: Chairman Harris and the Members of the House Committee on Natural Resources
From: Bailey Bass and Kamil Cook, Public Citizen
CC: Rep. Cody Harris, Rep. Armando Martinez, Rep. Trent Ashby, Rep. Jeff Barry, Rep. Cecil Bell, Rep. Brad Buckley, Rep. Caroline Fairly, Rep. Erin Elizabeth Gámez, Rep. Josey Garcia, Rep. Mary E. González, Rep. Ramon Romero Jr., Rep. Denise Villalobos, Rep. Erin Zwiener
Via hand delivery and online portal
Re: Statewide Data Center Water Use and Conservation Charge
Dear Chairman Harris and Members of the Committee:
On behalf of 30,000 members and supporters in Texas, Public Citizen appreciates the opportunity to testify on our concerns regarding data center water use in Texas. We believe the recommendations below, along with more information on the current threats to Texas water posed by data centers, will aid in developing policies that protect Texans.
Recommendations
- A data center moratorium is a commonsense policy that protects Texans—it gives communities and their elected officials time to properly analyze proposals, invite public comment and feedback to local/county government officials, and understand how it will affect the town/county. Counties should be given the ability to enact moratoria.
- The legislature should give counties the ability to increase their regulatory ability over data centers, especially in unincorporated parts of the counties, allowing for development moratoriums if needed until the state develops regulations by how data centers will operate in the future.
- The legislature needs to require that data centers report their direct and indirect water and energy use to the Texas Water Development Board. Data center usage is not included in the current 2027 water plan that will remain in place until 2032. Additionally, data center water use (and an approximation of indirect water use) should be reported to the Texas Commission on Environmental Quality. This information should be publicly available.
- Data centers should be required to employ the Best Available Control Technology (BACT) to decrease water demand by operating as energy efficiently as possible.
- The state should require that air or dry cooling be used by data centers to limit the amount of water needed for server cooling operations.
- Non-potable water like treated wastewater or brackish water should be used for cooling.
- The use of NDAs with public entities should be limited and severely curtailed. Texans should be able to find out even the basic facts of water and electricity consumption from these facilities.
- If built, data centers should be required to make community investments that offset the demand on local water resources, such as contributing to a fund that helps those least able to afford utility bills due to rate hikes.
- Data centers should be required to pay upfront costs for water infrastructure if it is needed for their operations.
- Almost 100 counties or parts thereof are not in a groundwater district. Aquifers and water resources need to be protected by requiring all counties of the state be placed within a groundwater district.
Establishing the Facts
Data centers are drawn to Texas for its lower business and operating costs, relatively low energy costs, and access to essential infrastructure. However, what is too often overlooked in the rapid expansion of data centers is the growing water crisis in Texas today. ClimateCheck reports that Texas ranks #10 for drought risk, while a large portion of the state is currently experiencing some level of drought.[1] Despite these challenges, Texas has the 2nd-most data centers proposed and under construction, behind Virginia, and is on track to become the world’s top data center market by 2030.[2]
Researchers from the University of Texas have recently stated that they believe that by 2040, data centers’ state water consumption could increase drastically from its current level of less than 1% to 3% or 9%.[3] Under higher-growth scenarios, data center water consumption could rival or even exceed the water footprint of a state’s entire manufacturing sector, which is 7% of statewide water use.
Direct and Indirect Water Consumption
When estimating the water footprint of data centers, both direct and indirect water use must be considered, or the total footprint will be understated. Direct water consumption refers to water consumed on-site for cooling, while indirect use includes water used in electricity generation. The balance between direct and indirect water consumption can vary significantly depending on cooling technology, workload, energy source, and climate conditions. The Houston Advanced Research Center estimates that in 2025, data centers in Texas consumed approximately 25 billion gallons of water, including direct and indirect sources.[4] The same report found that data center water demand is expected to rise to 29-161 billion gallons by 2030.
Given the increasing demand for Texas water, the state Legislature should ensure that these data centers do not jeopardize communities’ access to drinking water, especially in areas already experiencing drought. To do this, we recommend that the Texas legislature require data centers to use non-potable sources for cooling whenever possible. These include sources such as reclaimed water, wastewater, or highly saline groundwater.
Some industry leaders argue that the next generation of AI data centers will be less water-intensive because of advances in cooling technologies including air cooling and more efficient cooling system designs. Even with these advances, water intensive cooling technologies, like evaporative cooling, may continue to be used because they provide efficient heat removal, particularly during hot weather conditions. Furthermore, cooling technologies that reduce direct water consumption often require additional electricity, increasing indirect water consumption associated with power generation. As a result, data centers who adopt cooling technologies that rely more heavily on electricity, find that their water burden is shifted from onsite use to their electricity generation. This distinction between direct and indirect water consumption is important, because reductions in facility onsite water consumption does not mean that the same reductions are seen in the total water footprint of a facility.
As more data centers begin to incorporate electricity intensive cooling technologies, some developers are pursuing dedicated natural gas generation to serve large AI data centers. While these facilities may be owned or operated by separate entities, their primary purpose is to support data center operations. Therefore, the total water footprint can be obscured if only the data centers onsite water consumption is evaluated. Water use associated with co-located or dedicated power generation should be considered part of the broader impact of data center development. We therefore recommend that the Legislature require data centers to report their electricity and water use (both indirect uses and direct uses) to the Public Utility Commission and the Texas Commission on Environmental Quality, including the water and electricity consumption associated with any co-located or dedicated power resources.
Future Water Planning
One of the main obstacles to properly addressing current and future water demands from data centers is the lack of consistent public reporting, long-term planning, and transparency surrounding water consumption. Although accurate projections for future water demand depend on reliable information about current water use, Texas has limited publicly available data on water consumption and does not require the disclosure of projected water demand. In 2024, the Texas state board requested information on ground- and surface-water consumption data from 70 data centers.[5] Despite the law requiring disclosure of this information, only one-third of the data centers responded.
In Texas, water state plans rely on historical data, and without accurate information on data center water use, water planners lack a complete picture of future water demands. The water state plan’s reliance on historical data has resulted in the absence of data centers in the 2027 Draft State Water Plan, even as data center development continues to boom in Texas.[6] Finally, we recommend establishing a reliable system for tracking data center water consumption to accurately plan water demand across Texas.
With the fast-paced growth of the data center development across Texas, it is important that the Texas legislature has safeguards in place to ensure that the industry’s growth does not come at the expense of long-term water security. Greater transparency, stronger reporting requirements, and improved water planning are necessary to protect communities and manage future demand responsibly.
Thank you for the opportunity to provide this testimony, if you wish to discuss our position further, I can be reached by email at [email protected] or by phone at 512-477-1155.
Respectfully,
Kamil Cook, Clean Energy Associate
Bailey Bass, 2026 Summer Intern
Public Citizen
[1] See https://climatecheck.com/texas
[2] See https://www.statesman.com/business/technology/article/texas-data-center-market-2030-21367690.php
[3] See https://compass.beg.utexas.edu/files/publications/Water_Requirements_for_DC_White_Paper.pdf
[4] See https://harcresearch.org/wp-content/uploads/2026/01/Thirsty-Data-Water-Use-and-The-Projected-Data-Center-Boom-in-Texas.pdf
[5] See https://www.texastribune.org/2025/09/25/texas-data-center-water-use/
[6] See https://www.twdb.texas.gov/waterplanning/swp/index.asp