Mayor Johnson and Council Members,

My name is Christopher Celaya. I am an El Paso resident and the founder of Celaya Solutions Research LLC. My background is in electrical infrastructure — more than twelve years, including critical power systems at large data centers and switchgear manufacturing. I have read the public records behind the region's data-center projects and run the water and power math, and I am submitting that work, sourced and reproducible, for your consideration.

I am not against data centers or technology. I build the equipment they run on. My concern is narrow and factual: the City is approving facilities that consume large volumes of our water and power without enforceable limits, and is shifting the cost and risk onto residents. The draft Data Center Policy Framework is a good list of goals, but it has no teeth. It should be replaced with an enforceable ordinance.

The one question I ask you to answer on the record

El Paso Water provides on the order of 105 million gallons per day, with a documented regional surplus on the order of 8.71 million gallons per day. The Northeast El Paso facility alone is authorized for up to 1.5 million gallons per day — roughly 17.9% of that surplus — and no public document identifies the supply figure relied upon to find regional supply adequate. If that number cannot be shown with a citable source, the approvals rest on trust, not data.

What the public record now shows

The executed agreements for the Northeast El Paso project (counterparty WURLDWIDE LLC, d/b/a Statue LLC) show that the public commitment is far larger than the headline "80% tax break," while the protections a host city normally requires are absent:

• An 80% property-tax abatement for 10 years per phase (Chapter 312), plus a separate 80% property-tax grant for 15 years per phase with no dollar cap (Chapter 380), across a 35-year term and up to five phases;
• Up to $5,000,000 in Texas Economic Development funds and up to $7.5–9 million reimbursing the company's road costs, plus a waiver of nearly all impact, permit, and park fees, and the sale of roughly 1,039 acres of City land to the company;
• In return, a requirement of only 50 permanent jobs — total, not per phase, remote workers counting, at a wage floor near $16.43/hour;
• And, critically, no cap on water or electricity use anywhere in these contracts. Water terms were placed in a separate El Paso Water "Water and Wastewater Agreement" that is not part of the public deal, and there is no cost-causation requirement to keep the utility upgrades the project triggers off of residents' bills.

I do not raise these to single out one company; each project followed the rules that exist today. The point is that the rules are too weak, and the same pattern will repeat with the next facility unless the City sets enforceable, generally applicable terms now.

What I am asking the Council to do

1. Adopt an enforceable ordinance, generally applicable to all hyperscale data centers, in place of the non-binding framework. I have drafted and attached a model ordinance, written to be neutral and court-ready, that the City Attorney can review and refine. It requires a special permit and Council vote, a 1,000-foot buffer from homes and schools, a potable-water cap with reclaimed-water cooling, public metering and reporting, 100% applicant-paid cost causation, daily penalties, and a teardown bond.
2. Publish the water-supply number relied upon for data-center approvals, with its source. If the math cannot be shown, do not approve further capacity.
3. Require a cumulative regional water-and-power study — counting Meta, Wiwynn, and the adjacent Doña Ana County project together — before any new approval, phase, or incentive.
4. Make data centers pay 100% of the utility upgrades they cause, with no rate increases on residents, and require that the water/wastewater and interconnection service agreements be filed with the City and made public, redacted only as the Texas Public Information Act requires.
5. Require a decommissioning bond before operation, so an empty facility never becomes the public's liability.

Supporting documents

All of the following are public, sourced, and free to use, at celaya-solutions.github.io/Draft-Policy:

• Draft Data Center Ordinance (model city law) and a section-by-section Crosswalk to the City's draft framework;
• Evidence Record — the water-balance math, timeline, and an index of 68 public records;
• The executed Chapter 312, Chapter 380, and Stan Roberts / TED-funds records for the project.

I am available to brief Council, the City Plan Commission, or City staff at no cost. Thank you for your service and for considering this comment.

This comment is an independent submission and is not an official City of El Paso publication. The model ordinance is a draft for the City Attorney's review and is not legal advice. Every figure cited is sourced in the Evidence Record. Corrections welcome.