Culper

Masterplan

2. Existing conditions

Guthrie, King County, Texas.

2.1Location, land, and buildable area

The Atlas land map is the existing-conditions record: parcels, soils, 345 kV, gas, and water. Compiled numbers below (acoustic buffer, MAG vs plant water, turbine derate) sit on top of it. The northeast block is 23,200 acres under one owner. The campus lot is 3,254 acres; structures sit on 1,541 of them. The workforce camp (110 ac) and the wellfield envelope (3,640 ac) are on the plan and off this pad. The KMZ label of 773 acres is a map label, not a survey. ALTA replaces all of this.

Figure 2.1. Existing conditions on the northeast block. Atlas land map: parcels, soils, power, gas, water.

Lubbock, Abilene, and I-20 sit on the regional frame. The pad is the flat upland of West Big Field and Clear Country.

Figure 2.2. Regional frame. Lubbock, Abilene, I-20.
Figure 2.3. USGS-style topo of the northeast block. Campus on the upland.

The parcel minus exclusions (title, pipeline consultation, well setbacks, inundation, WOTUS buffers, cultural, FAA) is the buildable envelope. This study uses environmental elements already sited on the block.

Acoustic setback is modeled, not guessed. With OEM silencers the 50 dBA night contour sits at 396 m, inside the generation-island reservation. Skip the silencers and it jumps to 1.5 km and starts eating halls. Cost of the silencers is about $15.3M, inside owned generation.

Acres that vestWhat happens
2,500Studies complete, air permit in hand, gas agreement signed, construction started. First tranche of the option vests.
5,000First 100 MW running. Fiber lit to the long-haul network. Community fund active.
10,000200 MW running on firm pipeline gas. Tranche one fully vested.
23,000~500 MW campus. Grid interconnection application filed. Second tranche vests.
50,000Toward 3 GW on the Cottonwood corridor. Later tranches. Not Palo Duro.

Acreage that has not vested by its milestone date returns to the ranch automatically.

2.2Power access

Cottonwood–Nova Prime 345 kV double circuit, ~2,896 MVA/circuit, NE corner, <100 ft closest approach Record

The interconnecting TSP would be WETT, with AEP Texas the likely delivery provider, at the Helios structure 17 miles west. Oncor has no facilities on this corridor. ERCOT large-load pipeline frozen 2026-08-03; first utility MW P50 mid-2030 First power does not take that path. The candidate POI is the Cottonwood–Nova Prime corridor on the northeast corner. Island faults in this design: 26.5 kA MV / 87.1 kA LV. Utility 345 kV available fault is estimated at 31.5 kA. That number sizes the Phase 3 yard.

WETT screening study under NDA. Ask on day one even though we do not file.

2.3Gas access and on-site generation

16-inch, FERC CP25-531 certificate 2026-03-19, 80,000 Dth/d firm, ~8 mi, RRC T-4 07201 Record

Uncommitted capacity after the 2025 open season is the first commercial question. Interstate service is not yet in-service (no tariff through 2026-08-28). First power is a 9.5-mile lateral and 6 GE Vernova LM2500XPRESS+G4 DLE machines at 132.1 MW firm, burning 29.6 MMcf/d. Palo Duro’s 80,000 Dth/d nameplate fuels that tranche and nothing larger. The compiled campus is 350 MW IT and needs 78.9 MMcf/d; Atlas already draws the second feed. The campus fleet is 16 × GE Vernova LM2500XPRESS+G4 DLE (422.7 MW gross / 396.2 MW firm N+1) on 3 collector sections. Rental is the first-fire schedule bridge.

The machines are rated at ISO, and the site is not ISO

GE Vernova LM2500XPRESS+G4 DLE is a 34.5 MW machine at 15 °C and sea level. At the ASHRAE 0.4% design condition here, 104.4 °F dry bulb and 610 m elevation, it makes 26.42 MW. That is 23.4% off nameplate: 16.4% temperature and 7% altitude. 16 machines are needed to cover 372.74 MW of facility load with 5% reserve. A fleet sized on the nameplate would come up short on the design afternoon. The derate buys 3 extra machines, extra pads, extra fuel headroom, and extra emissions in the air permit.

16 x GE Vernova LM2500XPRESS+G4 DLE. Each makes 26.4 MW at 104 F and 610 m, not the 34.5 MW ISO nameplate, a 23% derate. Sizing on nameplate would have bought 13 machines and left the campus 56 MW short on the design afternoon

Six aeroderivative blocks, GSUs and fin-fan coolers
0102030ISO nameplateSite, 104.4 °F / 610 mISO nameplate: 34.5Site, 104.4 °F / 610 m: 26.4MW per machine16 machines · 423 MW gross on the design afternoon
Figure 2.4. Nameplate versus site rating.
Fuel price is a modelHeat rate 9150 Btu/kWh × (Waha $2.1 + assumed transport $0.6) = $24.71/MWh. Transport is a placeholder until the FERC tariff exists. About $77.8M/yr on 3,147,424 MWh and 28,799,036 MMBtu at CF 0.7, against 372.74 MW campus load.

2.4Water

Gateway GCD MAG is 49 AF/yr on the King County Blaine. Record The plant is dry for 95.9% of the year. It is not dry for all of it. Above 91.4 °F dry bulb the adiabatic pads have to come on or the loop cannot hold 41 °C supply. That is 357 hours a year, 4.1% of hours, and it costs 116 AF/yr. WUE is 0.0467 L/kWh. Calculated

The MAG covers 42.2% of that. Demand is 72 gpm against a MAG of 30.4 gpm, so 67 AF/yr has to come from import or a variance. Calling the plant “dry-cooled” in a lease does not change that number.

MAG 49 AF/yr is ~30.4 gpm, enough for camp domestic and fire but not for 116.1 AF/yr dry-plant demand (~72 gpm). Chemistry is gypsum (TDS thousands). Dry cooling is not optional; the remaining water is an import / GCD-variance / brackish-RO question, not a well-count question.

1001,000District MAGThis campus (dry / p…Evaporative campus (…District MAG: 49This campus (dry / pad-assist): 116.1Evaporative campus (closed): 4,000Acre-feet / year
Figure 2.5. Water, log scale. The district MAG, this campus on dry/pad-assist, and the evaporative alternative.

Working well yield 50 gpm · 2 wells if the MAG is not lifted · TDS 1,5006,500 mg/L (TWDB R376). RO recovery 0.6. Three test wells, 72-hour pumps, full metals + gypsum, GCD pre-application meeting. 90 days.

2.5Roads, logistics, fiber

TxDOT Childress District Super-2 through King/Cottle, $46.8M, complete late 2028 Record No rail in Dickens or King. Nearest BNSF is Childress, about 55–60 road miles. Bridge ratings on US-82 (Salt Fork Brazos / Croton Creek) and US-83 (South Wichita) remain to be confirmed.

Figure 2.6. Roads and towns. US-83 Super 2; nearest BNSF at Childress. Compiled context frame.

Cap Rock Telephone Cooperative FTTH at Guthrie; ~20 Gbps purchased transit; no published long-haul in Dickens/King Two diverse laterals are on the plan: Childress ~57 mi and Lubbock ~93 mi, plus a campus ring and two MMRs. Dallas RTT ~5–8 ms once built. Cap Rock is construction connectivity, not DC transport. A single lateral reads as Tier-2-only to tenants.

County population ~265. Peak crews in the thousands need the 110-acre camp east of the perimeter.

CommunityFinding
County population~265
Census; main.tex Appendix G.
Record
In-county hospitalNone
Drive to Childress ~55–60 road miles is the working figure, not a timed isochrone.
Record
RailNone in King or Dickens
Nearest BNSF Childress.
Record
School districtGuthrie CSD
Amenity / tax conversation, not modeled.
Plan
ISO PPC / ESDPending
Rural fire flow and brigade evaluation.
Pending
Workforce housing110 ac camp, 2.5 mi east of perimeter
Peak crews in the thousands in a county of ~265.
Plan
Economic impact (RIMS II / IMPLAN)Not this Class 4
BEA RIMS II is free; run when the owner wants a number for the court.
Pending

2.6Environment, species, cultural resources

Lesser prairie-chicken listings withdrawn Feb 2026; new status review open. Verify live in IPaC before filing. Record Nothing on the public list stops a 2026 start. The live chip is LPC status review. Carry an HCP option, do not price a clearance.

SpeciesStatusIf we are wrong
Lesser prairie-chicken
Range includes NW Texas. Habitat is mixed-grass / shinnery, so possible on the block but not proven.
Not federally listed (vacated). 12-month status review open (91 FR 9547).Relisting during design: seasonal lek windows, possible HCP. 6–18 months, $5–20M Class B.
Texas horned lizard
Rolling Plains still has pockets. Construction take is a state permit question.
State threatened (TPWD). Not federally listed.Relocation protocol, seasonal ground-clearing. Weeks, not the critical path.
Monarch butterfly
Milkweed in draws. Avoid treating the pad as habitat restoration theater.
ESA candidate / under review at various times. Not currently a take prohibition here.BMPs in the SWPPP.
Whooping crane
King County is inside the broad Great Plains flyway. Wetland stopovers are the draws we already buffer.
Federally endangered. Migration corridor is hundreds of km wide.Lighting and guy-wire specs; no new wetland fill in Cottonwood / Buford. Already in Ω_build.

King and Dickens: no NFHL mapping (Zone D). Site-specific H&H is a day-one workstream. Atlas 14 at the centroid: 24-h 100-yr 7.79 in, 25-yr 5.84, 10-yr 4.7. 6-h 100-yr 5.62 in. Record

Building-area soils: Carey loam and St. Paul silt loam. Linear extensibility 3.4–4.5%, moderate shrink-swell, not Vertisol. Gypsum in mapped building-area horizons is zero; gypsum lives in the breaks, which are excluded. A boring program is still required. THC Atlas is restricted; Antiquities Code can trigger if MMD/TIRZ is used.

Critical-issues analysis

What is known on the ground, what is partial, and what still has to be obtained.

TopicFindingNext
T&E / habitat EstimateLPC listings vacated; status review open. Horned lizard state-threatened. Whooping crane flyway is a lighting and guy-wire issue. Desktop from FWS/TPWD, not official IPaC.Official IPaC on the drawn pad. One afternoon. HCP option if LPC returns.
Cultural / Antiquities / §106 PendingTHC Atlas restricted. Public nexus (MMD/TIRZ or 404) can trigger survey.Commission archaeologist.
Floodplain EstimateKing/Dickens unmapped (Zone D). Atlas 14 100-yr 24-h = 7.79 in at centroid.Site-specific 2D H&H 5/25/100-yr.
Wetlands / WOTUS PendingEphemeral draws. 100 m no-build on Cottonwood Creek and Buford Branch pending AJD. SWT vs SWF split by drainage.Delineation + AJD. NWP vs individual is the threshold.
Slopes / grading PendingAtlas: pad <3%. Cut/fill and FFE are not computed.3DEP/ALTA surface; grading program after H&H.
Prime farmland PendingBuilding-area SSURGO is Carey loam / St. Paul silt loam. Farmland classification not pulled as a legal FPPA finding.NRCS CPA-106 if a federal nexus exists.
Hazardous materials / O&G legacy Pending~92 dry holes, zero active under the block. Live permit API 42-269-32650 in the block. Two RRC locations flagged for Phase II in the study list.Phase I ESA (E2247-23) then Phase II on hits.
Acoustics EstimateISO 9613-2 far-field. With OEM silencers, 50 dBA night holds at ~400 m. Without silencers the contour extends much farther.OEM octave-band Lw. Silencer cost is inside owned generation, not a new WBS.
Airspace / eagles EstimateSheppard/Dyess training airspace. Part 77 if stacks/towers. Whooping crane is a flyway lighting issue.FAA OE/AAA if stacks >200 ft; official IPaC includes eagles.

Buildable-area exclusions

LayerRuleSource
Ephemeral drainages Pending100 m no-build on Cottonwood Creek and Buford Branch pending AJDAtlas environmental elements
Gypsum / DQG breaks RecordBuilding-area SSURGO horizons show zero gypsum; breaks already excluded from Ω_build cartoonSSURGO TX269/TX125
Wells / live permit RecordSetbacks from RRC locations; live permit API 42-269-32650 in the blockRRC GIS / DD memo
Pipelines PendingConsultation zone; not a surveyed easement polygonPHMSA/RRC; ALTA will replace
Title / minerals PendingSchedule B exceptions become exclusions once ALTA exists. Mineral estate is dominant.Texas accommodation doctrine
Acoustic Estimate50 dBA night contour with 15 dB OEM silencers ≈ 400 m from the island. Without silencers ≈ 2.7 km, which is a pad impact.ISO 9613-2 model; OEM Lw still confirms
FAA / airspace PendingPart 77 if stacks or towers exceed notice criteria14 CFR 77
345 kV ROW RecordCottonwood–Nova Prime on the NE corner; no-build inside the existing ROWHIFLD vs owner KML

2.7Jurisdiction and permitting reality

Unincorporated. Under LGC Chapter 233 a Texas county has no general authority to adopt a commercial building code. King County has no building department. TDLR carries the NEC statewide. Insurer standards (FM 1-28, 1-34, 4470) are the de-facto envelope.

Code editions: NEC 2023, IBC 2021, IFC 2021, IMC 2021, IPC 2021, IECC 2021, TAS 2012. Selected

WhoRole
USACE Tulsa / Fort WorthCWA §404; Red River drainages → SWT, Brazos → SWFPending
USFWSESA §7/§10; IPaC official list once footprint is drawnPending
TCEQAir PBR / standard permit / NSR; TPDES; water rightsPlan
TPWDState T&E lists; TXNDD data request (fees possible)Pending
FEMANFIP/NFHL; National Risk Index; King/Dickens unmapped Zone DRecord
PUCT / ERCOTSB6 large-load; Project 58317 / 58481; queue frozen 2026-08-03Record
Railroad CommissionWells, T-4 lateral, UICRecord
Gateway GCDKing County annexed 2018; GMA 6; MAG 49 AF/yr BlaineRecord
King County Commissioners CourtLGC Ch. 232 platting; no building department (LGC Ch. 233)Record
TxDOT ChildressUS-82/83 access; Super-2 underway, complete late 2028Record
FAA / DoD ClearinghousePart 77; Sheppard/Dyess training airspacePending
THCAntiquities Code; Atlas restrictedPending
TDLRStatewide NEC; licensed electricians, the actual electrical AHJRecord
Insurer (FM Global class)FM 1-28 wind, 1-34 hail, 4470 roofing, the de-facto envelope where there is no county building codeSelected

Incentive instruments: TIRZ (Tax Code Ch. 311); Municipal Management District (LGC Ch. 375); County Ch. 381 economic-development agreements; JETI Act (HB 5 / Gov't Code Ch. 403 Subch. T) covers dispatchable generation, manufacturing, critical infrastructure. Renewable generation and storage excluded.; Data-center sales-tax exemption (§151.359); Freeport exemption. Separate plats for campus, generation, and any later solar/BESS so each asset can be financed and incentivized apart; infrastructure by cross-access easements. A solar/BESS plat would not qualify for JETI; the gas plant and campus may. Plan

Legislative-risk scenarios

ItemIfThen
ERCOT large-load queue freeze (Abbott 2026-08-03) RecordStays frozen past 2027No utility MW before ~2030 P50. Campus is BTM.
SB6 / proposed PUCT 25.194 security PlanFiled as written~$50k/MW posted + $50k/MW non-refundable. 350 MW is about $35M at risk. Do not file until Phase 3.
LPC status review RecordRelisted during designSeasonal windows, possible HCP. Carry as Class-B, not a clearance.
WOTUS jurisprudence PendingDraws become jurisdictional404 individual vs NWP. Buffers already carried pending AJD.
JETI (HB 5) eligibility split PlanAs writtenGas plant and campus may qualify. Solar/BESS plat does not. Separate plats.
King County MAG 49 AF/yr RecordUnchangedEvaporative cooling is closed. Dry campus still needs brackish or import water for the 116 AF/yr band.
No county commercial building code RecordUnchangedTDLR + insurer (FM) are the envelope. Code editions are a manifest field.

Wind (ASCE 7-22 interior contour): RC II 105 mph, RC III 115, RC IV 120, Exposure C, SDC A. Tornado Chapter 32 applies at III/IV. Estimate Must confirm on ascehazardtool.org before structural issue. Tornado Ch. 32 applies at RC III/IV.

2.8What we know, what we derived, what remains outstanding

Known

  • Single-owner surface (Pitchfork Land and Cattle, Delaware 1933).
  • 345 kV Cottonwood–Nova Prime double circuit on the NE corner (<100 ft).
  • Palo Duro 16-inch, FERC-certificated, ~8 mi, 80,000 Dth/d firm nameplate.
  • Gateway GCD MAG 49 AF/yr. No FEMA NFHL (Zone D). King population ~265.
  • Queue frozen 2026-08-03. Cap Rock FTTH at Guthrie; no published long-haul in-county.
  • Atlas 14 24-h 100-yr = 7.79 in at the centroid.

Derived from this design

  • 1,844 racks from 350 MW at 190 kW planning across 3 × 116.66666666666667 MW zones. Facility 372.74 MW / 408.04 MVA.
  • 16 turbines, because 34.5 MW ISO is 26.42 MW at 104.4 °F and 610 m.
  • 151 CDUs and 351 fluid-cooler modules from 52,608 hourly ERA5 pairs. Mechanical PUE 1.0179, total PUE 1.064.
  • 116 AF/yr from 357 pad hours, which is 2× the Gateway GCD MAG.
  • 160 padmount transformers at 3,750 kVA and 372 PCUs, on 3,127 nodes and 3,644 circuits.
  • 79 MMcf/d and 1,528,071 tCO2/yr, which is 20.4× the 75,000 tpy PSD greenhouse-gas trigger.

Counts, water, fuel, and emissions are taken from the same electrical, thermal, and generation basis.

Outstanding items

  • Palo Duro uncommitted capacity and the FERC tariff, the one commercial number that still gates first fire.
  • Official IPaC list on the drawn pad (desktop species model is in §2.6).
  • IEEE 81 Wenner (IEEE 80 screen is in §7.2).
  • Carrier IRUs; US-82/83 bridge ratings.

27 outstanding items in the gap register, 35 total. Full list in Appendix D/E/H.