Market · Texas digital infrastructure
Dallas builds. Houston supplies a different bench.
Two metros, one statute book, and two completely different legal capabilities. For the general counsel staffing a Texas campus, picking the wrong city does not show up in the salary line. It shows up as months of outside-counsel dependence on the one file that can stop the project.
One state. Two shopping lists.
A general counsel searching for data center legal counsel in Texas is usually asking a state-shaped question about a city-shaped problem. Across 500 structured interviews with Dallas in-house lawyers and legal leaders, the metro split below is the shape that keeps recurring. Pick the lens that matches the file that can stop your project this quarter — each one buys a different lawyer, and five of the seven sit on only one side of that split.
Oncor reported 650 active large commercial and industrial interconnection requests at the end of 2025. CenterPoint Energy Houston Electric reported 12.2 gigawatts of firmly committed industrial load in its first-quarter 2026 report. Requests and commitments are different objects, and they buy different lawyers. Read the label before the number.
Five of these lenses point at a specific bench and two point at a delay. The two hiring briefs are set out side by side below.
- 255 GW
- Data-center interconnection requests in Oncor's territoryApplied-for, at 31 December 2025; over 18 GW more from other industry
- Oncor 2025 results, 26 February 2026
- $3.5B
- Customer collateral posted to OncorSecurity for generation and large-load interconnection positions
- Oncor, as of 25 February 2026
- 75 MW
- Statutory large-load threshold in TexasThe line above which Senate Bill 6 standards attach
- PURA 37.0561, SB 6, 20 June 2025
- 100+
- Local Texas data-center ordinances consideredSince 1 July 2025, overwhelmingly in municipalities
- MultiState, 19 August 2026
The state writes one rulebook. The metros hire two benches.
Every legal instrument that governs a Texas campus is a state or federal instrument. Almost none of the people who practice them are interchangeable across three hundred miles.
A chief legal officer looking at Texas from outside it sees a single jurisdiction: one legislature, one utility commission, one environmental agency, one grid. That reading is correct and it is useless. The Public Utility Commission of Texas and the Texas Commission on Environmental Quality do sit above both metros. But the lawyers who actually appear before them, and the lawyers who actually close a campus, have been trained by two different local economies for forty years, and a hiring brief that ignores that buys a title instead of a capability.
Dallas grew a delivery bench because Dallas grew buildings. Oncor Electric Delivery reported 650 active large commercial and industrial interconnection requests at 31 December 2025, and separated them carefully in the same announcement: approximately 255 gigawatts of that queue came from data centers, at least 38 gigawatts met the qualification standards for the 2026 Regional Transmission Plan, and the transmission projects it was advancing through ERCOT’s Regional Planning Group were expected to support roughly 14 gigawatts of new large load. Three numbers, three different meanings, one utility. The legal work that follows the third number is real estate, construction and procurement, and it is done by people who live where the buildings are.
Houston grew an energy bench because Houston grew power and the contracts that move it. CenterPoint Energy Houston Electric reported 12.2 gigawatts of firmly committed industrial load in its first-quarter 2026 results, expected 8 gigawatts of data-center load to be energized by 2029, and had 3.5 gigawatts of it under construction. Notice the vocabulary. Oncor publishes a queue; CenterPoint publishes commitments, because on the Gulf Coast the interesting question has always been whether the electron is contracted, not whether the slab is poured. The lawyer who is fluent in that question is an energy, projects and infrastructure-finance lawyer, and Houston has spent two generations making them.
Land decidesGrid decides
- Site control and entitlement Assembly, options, platting or zoning, water and wastewater conditions, easements, incentive agreements. Local, municipal, and adversarial in public. This is where a campus becomes a legal address.
- Construction and delivery Design agreements, engineering and procurement contracts, owner-furnished equipment, schedule liquidated damages, lien and claim exposure. Commercial, private, and mostly negotiated in a room.
- Interconnection, tariff and offtake Study milestones, contribution in aid of construction, security, curtailment protocols, co-location approval, power purchase. Filed, regulated, appealable — and now the gate the others wait behind.
The order of those three gates is what changed. For most of the last decade a Texas campus cleared the first two and treated the third as a commercial formality with a utility account manager. In 2026 the third gate is the one with a statute, a rulemaking, a cluster study and a state audit attached to it — which means the capability a company needs most urgently is the one Dallas operators were least likely to have hired. Across 500 structured interviews with Dallas in-house lawyers and legal leaders, 118 of the 214 respondents sitting inside operator, developer and delivery legal departments over a 24-month window told Sartori that the single longest unplanned delay in their most recent project was a power or interconnection workstream, not a land or construction one. Only 31 of those 214 said their department held any energy-regulatory capability in-house at the time.
Texas did not build one data center legal market with two offices. It built two markets that now need each other on every project.
The Dallas requisition is a delivery requisition, and it is posted in public.
Operators headquartered in the Dallas-Fort Worth metro run legal departments that look like real-estate and construction functions with a commercial-contracting front end. That is visible in what they advertise, and in what they do not.
The clearest evidence of what a market hires is what it posts. Between November 2025 and August 2026, public postings for in-house legal seats at Dallas-headquartered colocation and interconnection operators asked for hyperscale commercial contracting at twelve to twenty years of experience — leases, master services agreements, service-level agreements and license agreements — alongside real estate development, construction and infrastructure procurement, campus easements and entitlement support. A separate seat at the same class of employer asked for private-funds work: private placement memoranda, partnership agreements, side letters and investment-management agreements. Another asked for corporate and capital-markets coverage with real-estate-investment-trust issues named as a plus.
Read that list as a general counsel would. It is the legal infrastructure of an owner-operator: sell the capacity, buy the land, build the shell, procure the equipment, fund the vehicle, report to the market. Energy appears in it — one Dallas posting in that window sought a senior director for corporate counsel, energy, at seven or more years, covering power purchase agreements, utility service agreements, interconnection and development agreements — but as one seat inside a delivery department rather than as the department’s spine. That is a rational structure for the market Dallas was in 2023. It is an exposed structure for the market Dallas is in now.
| Buyer | Where the seat sits | Practice label actually hired | In-house or bought in |
|---|---|---|---|
| Colocation and interconnection operators | Dallas headquarters and campus offices | Hyperscale leasing, master services and service-level agreements, real estate development, construction, procurement, funds and REIT work | In-house, with outside counsel kept for hearings |
| Hyperscale campus developers | Houston general counsel, Dallas delivery alumni | Land use, environmental authorization, energy regulatory, real estate and construction | In-house head of legal plus Houston energy firms |
| AI-cloud and converted crypto operators | Mixed national and Dallas in-house, Texas campuses | Entitlements, EPC and construction claims in-house; ERCOT, offtake and project finance bought outside | Both |
| Hyperscalers | National legal departments; Texas execution local | Land use, Comptroller certification, water, PUCT dockets, co-location and offtake | Firm-heavy in Texas |
| Transmission and distribution utilities | Dallas and Houston in-house regulatory counsel | Energy regulatory, rates, large-load interconnection, transmission planning | In-house plus relationship firms |
| Independent power producers and generators | Houston and Irving commercial legal | Power purchase agreements, wholesale market, interconnection, project development | In-house commercial plus Houston energy firms |
| Infrastructure funds and credit providers | National funds lawyers, Texas local counsel | Project finance, real estate finance, joint ventures, energy regulatory as local counsel | Firm, with a small in-house core |
Why the delivery bench concentrated here
Dallas is where the buildings and the leases are, and the commercial property researchers who track that inventory measure it directly. CBRE put Dallas-Fort Worth colocation inventory at 1,067.3 megawatts at the end of 2025, with just 26.0 megawatts marketed as available and 470.8 megawatts absorbed across the year, in the H2 2025 trends work it published in February 2026. A market that tight is a market in which the scarce legal skill is closing space quickly and cleanly: form leases that survive a hyperscale counterparty’s redlines, service-level credits that an operations team can actually meet, and construction contracts that keep a delivery date.
That inventory also explains the land-use bench, because in the Dallas ring the cities are the gatekeepers. MultiState counted at least 100 local Texas ordinances considered since 1 July 2025, and the Dallas-Fort Worth municipalities supplied a disproportionate share of them: a special-use permit regime in Lewisville adopted in June 2026, a light-industrial classification with a conditional-use permit and a residential buffer in Forney in April 2026, and a dedicated data-center and storage framework in Mesquite in July 2026. Each of those is an application, a staff report, a commission hearing and a council vote, and each of them is a file a head of legal either staffs or outsources.
Sartori’s Dallas file has the same shape. Of the 22 in-house searches closed in Dallas over the trailing three years, on a desk that has worked this market for more than 10 years, 14 were real-estate, construction, procurement or commercial-contracting seats and 5 were corporate, funds or capital-markets seats. Three were energy. The counter-offer incidence on the Dallas in-house book runs at 30 percent and the median gap between offer and acceptance is 12 working days, which tells a general counsel something useful: in Dallas, the competition for a delivery lawyer is real but the close is fast. It is the brief, not the negotiation, that goes wrong here.
Houston does not have a data center market. It has the bench that unlocks one.
Measured as buildings, Houston is a modest secondary market. Measured as legal capability, it holds the practice that every Texas campus now depends on — and it mostly does not sell it as an in-house data-center title.
It is worth being blunt about the buildings, because the buildings are the reason the Houston bench is undervalued by companies shopping for it. CBRE’s H1 2025 Houston profile, published on 8 September 2025, described a market whose colocation vacancy had risen to 19.7 percent after a single operator delivered capacity, with only 15 megawatts of new colocation scheduled to land by the end of 2026. On that measure Houston is not where the sector is building. Anyone reading only that measure will conclude there is no Houston legal market worth recruiting from, and will be wrong by a wide margin.
The Houston capability is not attached to Houston buildings. It is attached to the questions a campus asks anywhere in the state: can this load be energized, on what terms, at whose cost, with what security, and who owns the generation behind the meter. Those are Public Utility Regulatory Act questions, ERCOT protocol questions and project-finance questions, and the lawyers who answer them for a living have spent careers on refineries, petrochemical expansions, midstream systems, merchant generation and the financings that carried all of it. The vocabulary transferred almost without translation.
Employer-specificMarket-portable
- The lease book Form documents, negotiated positions, credit policy and pricing discipline that belong to one operator’s commercial model. Valuable, deep, and largely rebuilt from scratch when the lawyer changes employer.
- The construction program Contract suite, vendor relationships, claims history and delivery culture. Partly portable as method, rarely portable as leverage, and sensitive to the region a lawyer learned it in.
- The regulatory record Dockets appeared in, tariffs argued, protocols drafted, financings closed. Institutional memory that belongs to the lawyer rather than to the employer, and the reason a Houston hire is productive in weeks.
The scale of what Houston’s transmission and distribution utility is now carrying makes the point without any recruiting argument attached. CenterPoint told investors on 28 July 2026 that it had submitted more than 17 gigawatts into the Batch Zero process and expected roughly 14 gigawatts of it to qualify as base or studied load, against a Houston-area system peak near 21 gigawatts, with about $900 million of customer cash commitments and deposits standing behind those positions. Every one of those positions carries tariff terms, a contribution-in-aid-of-construction calculation, a security instrument and a study interface. That is a legal product, and it is not a real-estate product.
The same is true one layer down, where the campus makes its own power. Texas has no state siting statute for these facilities and no state environmental policy act; the principal state approval for a privately generated campus is an air authorization from the Texas Commission on Environmental Quality. A standby fleet can sit under the permit by rule at 30 TAC 106.511, which requires no registration and no fee where its conditions are met. Firm on-site generation goes a different route, through the standard permit for electric generating units whose natural-gas-engine variant took effect on 30 January 2025. Floodlight reported on 9 July 2026, from Texas Commission on Environmental Quality records, that at least 38 Texas data centers had taken minor-source authorizations since 2024, covering more than 2,100 backup diesel generators. Knowing when a fleet has walked out of a permit by rule and into new source review is an environmental-and-energy skill. It is not something a colocation lease lawyer has ever needed.
Sartori’s Houston telemetry reads accordingly. Of the 19 in-house searches closed in Houston over the trailing three years, 11 were energy-regulatory, wholesale or project-finance seats, and 6 of those eleven were filled for employers whose asset sat outside the Houston metro entirely. Counter-offer incidence on the Houston in-house book runs at 26 percent, below the Dallas figure, and the median offer-to-acceptance gap is 13 working days. Across 275 structured interviews with Houston in-house lawyers and legal leaders, 96 of the 141 respondents sitting in energy, projects or infrastructure-finance functions over an 18-month window said they had been approached about digital-infrastructure work in the preceding year; 34 of those 96 said the approach had come from an employer with no Texas asset at all. Houston is being recruited out of, not into.
A lease book belongs to the employer who built it. A docket record belongs to the lawyer who argued it.
Interconnection stopped being a commercial conversation.
Between June 2025 and August 2026 the Texas legislature, the utility commission, the grid operator and the Governor's office each did something to the same file. A general counsel who staffed against the 2024 version of it is staffing against a document that no longer exists.
Senate Bill 6 of the 89th Legislature was signed and took effect on 20 June 2025. It added sections 37.0561, 39.169 and 39.170 to the Public Utility Regulatory Act and amended section 35.004, creating statutory interconnection standards and cost-contribution rules for large loads, a review process for co-location with existing generation, and curtailment protocols that a utility administers during firm load shed for large loads interconnecting after the end of 2025. The threshold is 75 megawatts. Below it, very little changed. Above it, a Texas campus acquired a regulator.
The commission then began writing the detail, and the detail is where the hiring consequence lives. In Project 58481 the Public Utility Commission of Texas published a draft of 16 TAC 25.194 for comment on 12 March 2026. As summarized by counsel writing on it on 17 March 2026, the draft would impose a non-refundable interconnection fee of $50,000 per megawatt, financial security of a further $50,000 per megawatt, study fees of $100,000 for requests between 75 and 250 megawatts and $300,000 above that, full contribution in aid of construction for radial and substation costs, and disclosure of site control, air permits and backup generation. Whatever the final text says, the shape is fixed: a large-load request is now a credit instrument. Somebody in the legal department has to negotiate, post and occasionally forfeit it.
A separate rule handled the campus that brings its own generation. The commission adopted 16 TAC 25.205 on 26 March 2026 in Project 58479, setting a 120-day ERCOT study followed by a 60-day commission decision window, with an application deemed approved if the commission does not act. A deemed-approval clock is not a document a real-estate lawyer has any reason to have read. It is exactly the kind of clock an energy-regulatory lawyer watches for a living.
A utility commercial fileA contested regulatory file
- The bilateral era A service agreement, a facilities extension, a deposit and an account manager. Negotiated privately, on commercial terms, by whoever in the department handled utility contracts — usually the same lawyer who handled the lease.
- Statutory standards A legislature writes interconnection standards, cost contribution, co-location review and curtailment duties into the utility statute, and a commission opens rulemakings to give them shape. The counterparty is no longer only the utility.
- Cluster study and state audit Requests are grouped and studied together, classifications are noticed, milestones are advocated for, and a statewide verification sits in front of all of it. The file now has a docket number, a calendar and an appeal route.
The grid operator changed the process shape next. On 18 June 2026 the Public Utility Commission of Texas approved ERCOT’s Batch Zero process, grouping qualifying loads of 75 megawatts and above into a single system-wide study rather than studying each request in series; ERCOT was tracking more than 438 gigawatts of large-load requests at that point, nearly 90 percent of them data centers, as Utility Dive reported on 22 June 2026. Reliability rules followed: Utility Dive reported on 13 July 2026 that the commission had approved ride-through obligations for large computational loads under NOGRR 282, after ERCOT recorded 28 events since the start of 2023 in which such loads tripped off by 100 megawatts or more during voltage or frequency excursions. Contesting a disconnection order and designing a compliant ride-through posture is protocol work.
Then the state stopped the clock. On 3 August 2026 the Governor of Texas directed a comprehensive verification and audit of data centers advancing through the ERCOT interconnection process, with no project to move forward until it was complete, and with the audit asking for projected consumption, on-site generation, water source, cooling technology, community-impact measures, ownership and control. ERCOT postponed its Batch Zero classifications the same day by market notice. Read the audit questionnaire as a staffing document and it is unambiguous: it cannot be answered by a real-estate department, and it cannot be answered by an energy department either. It needs tax, energy, water, land use and corporate ownership in one file, which is precisely the combination that sits in two cities.
A connection request used to be a contract negotiation. It is now a filing, a fee, a security package and a place in a queue somebody else controls.
The disclosed bands sit in one metro, and that is the finding.
Public postings price the Dallas delivery bench precisely. The Houston capability barely appears as an in-house data-center title at all — which tells a general counsel where the build-versus-buy line currently sits.
Between November 2025 and August 2026, in-house legal seats attached to data-center work were advertised with published bands in the Dallas metro and, as far as public postings show, essentially not at all as Houston data-center titles. A general counsel should read that asymmetry as information rather than as an accident. Dallas operators employ this capability, so they must post and band it. Houston’s equivalent capability sits at law firms, at independent power producers and inside utility regulatory departments, where it is either bought by the hour or carried under an energy title that never mentions a data center.
Dallas litigation counsel, interconnection operator
Two to four years. Commercial, employment, real estate and government enforcement, with data-center experience preferred.
Employer posting, Dallas, 2026The internal spread across those Dallas seats is the more interesting number. The litigation seat topped out at $233,000 and the funds seat at $300,000 at the same class of employer, in the same metro, in the same year: a gap of about 29 percent that has nothing to do with seniority in the conventional sense and everything to do with which part of the capital structure the lawyer touches. The energy seat sat between them at $260,000, which is itself worth noticing, because that is a Dallas employer paying below its funds band for the capability that its own critical path now runs through.
A chief legal officer at a fund-backed campus developer put the consequence plainly to us: the company had budgeted a delivery lawyer and discovered it needed a regulatory one, and by the time it understood that, the energization date had already been committed to an investment committee. Sartori’s Dallas mandate telemetry supports the pattern rather than the anecdote. Of the 22 in-house searches closed in Dallas over the trailing three years, 5 stalled at least once past ninety days, and in 3 of those five the block was on our side of the table: we shortlisted delivery lawyers for a seat whose critical path had already moved to interconnection, and the client was right to send the list back. That is a mapping failure, not a market failure. Our Dallas file records admission, employer and practice label; it does not record who has actually appeared in a commission docket, because no public register does.
Two hiring briefs, side by side.
Same state, same statute, same grid operator. The instruments that actually consume a legal department's week are almost entirely different, and so is the person you should be interviewing.
| Dimension | Dallas-Fort Worth | Greater Houston |
|---|---|---|
| The instrument that stops a project | A city council vote, a special-use permit condition, a construction claim | An ERCOT study milestone, a large-load tariff term, an air authorization |
| Land-use regime | Municipal zoning inside city limits; annexation and extraterritorial jurisdiction on the fringe; counties cannot zone | No zoning at all inside the city; Chapter 42 platting, deed restrictions, floodplain permits |
| Water | Municipal utility contracts and a wholesale raw-water district, with closed-loop cooling now a live condition | Groundwater and subsidence districts, municipal utility districts, drainage and detention |
| Wetlands district | U.S. Army Corps of Engineers, Fort Worth District | U.S. Army Corps of Engineers, Galveston District, with coastal regional conditions |
| Where the legal seat sits | On the company payroll, posted publicly, banded | At firms and at generators; rarely posted as a data-center title |
| What a hire brings with them | A lease book and a construction program, both partly employer-specific | A regulatory record and a financing structure, both portable |
| Failure mode of the wrong hire | A campus that is entitled but cannot be energized on schedule | A grid position that is secured but cannot be built out on schedule |
You are hiring somebody who can get a building entitled, contracted, built and leased inside a municipal system that has recently learned to say no.
- Test the municipal record. Ask which councils and commissions the candidate has actually appeared before, and what the conditions were. A Dallas-ring campus lives on hearings, and hearing experience does not appear on a transactional CV.
- Ask about annexation and jurisdiction. Since SB 2038 took effect on 1 September 2023, landowners can petition or vote for release from a city’s extraterritorial jurisdiction, which changes who regulates a fringe site mid-project.
- Buy the water file. Fort Worth’s data-center package proposes closed-loop cooling and prices connection against a water-loading study, and the raw water behind it comes from a wholesale district contract, not from the city alone.
- Check the wetlands district. A Dallas-metro site talks to the Fort Worth District of the Army Corps of Engineers; the 2026 nationwide permits published in the Federal Register on 8 January 2026 name data centers expressly, and district conditions are not interchangeable.
- Keep a litigator reachable. County pauses are legally fragile because Texas counties generally cannot zone, and the vested-rights and takings arguments that follow them are litigation, not land-use advice.
You are hiring somebody who can hold a regulated position: a study milestone, a tariff term, a security package and an air authorization, in front of agencies that publish everything.
- Ask for docket numbers. A candidate who has genuinely practiced here can name the proceedings they worked and the position they argued. A candidate who has read about them will describe the policy instead.
- Separate transactional energy from contested energy. Drafting a power purchase agreement and carrying a contested matter through a hearing are different muscles, and only one of them survives an intervenor.
- Confirm the appeal route is understood. Standard permits and permits by rule carry no contested-case right at all; where a hearing is available, the draft permit is prima facie proof and the hearing is time-capped, with state-agency appeals now running to the Fifteenth Court of Appeals.
- Test the flood literacy. Inside unincorporated Harris County the County Engineer administers floodplain development permits and the flood control district sets criteria without regulating development. A candidate who conflates the two has not done a Houston-area site.
- Price the portability honestly. This bench is being approached by employers with no Texas asset, so a Houston offer competes with a national market rather than a local one.
One boundary is worth drawing before a brief goes out. Neither of these two benches is the bench that Northern Virginia sells, and neither of them is the bench that has followed the West Texas campuses now dominating the state’s construction figures. A company recruiting for a Dallas-Fort Worth or Greater Houston seat is recruiting from a pool that those markets are also fishing in, and paying a Texas metro premium for a lawyer whose record was built somewhere else buys the salary without the local instrument. A Texas brief that says Texas has not yet said anything a candidate can be measured against.
How a general counsel briefs a search for data center legal counsel in Texas.
Design the brief backwards from the gate that can move your date, then decide honestly which half of the capability you will carry and which half you will rent.
| Instrument | Date | Issuing body | Where it bites | Capability it forces |
|---|---|---|---|---|
| Senate Bill 6 (PURA 37.0561, 39.169, 39.170) | Effective 20 June 2025 | Texas Legislature | Both metros, at 75 MW and above | Energy regulatory counsel who can brief PURA and structure behind-the-meter generation |
| Draft 16 TAC 25.194 interconnection standards | Published 12 March 2026 | Public Utility Commission of Texas | Both metros; the money lands in Houston-style finance | Energy regulatory plus infrastructure finance able to post and forfeit security |
| 16 TAC 25.205 co-located net metering | Adopted 26 March 2026 | Public Utility Commission of Texas | Houston-weighted; merchant generation is the Gulf Coast product | PUCT docket practice with a project-finance overlay |
| Batch Zero cluster study (PGRR145) | Approved 18 June 2026 | ERCOT, approved by PUCT | Both metros, at 75 MW and above | ERCOT protocol counsel on maturity, site control and attestation |
| Statewide data-center verification and audit | Directed 3 August 2026 | Office of the Governor of Texas | Both metros, before any project advances | A cross-desk answer: tax, energy, water, land use and corporate ownership |
| Municipal zoning, special-use permits and moratoria | Fort Worth process initiated 11 August 2026 | Home-rule cities in the Dallas-Fort Worth ring | Dallas metro only; Houston has no equivalent | Municipal land-use counsel and, where a pause is imposed, vested-rights litigators |
| Chapter 42 platting and Chapter 19 floodplain | Current, no-zoning letter reissued January 2026 | City of Houston and Harris County Engineer | Houston metro only | Platting, variance, deed-restriction and floodplain counsel |
| TCEQ air authorization for on-site generation | Gas-engine standard permit effective 30 January 2025 | Texas Commission on Environmental Quality | Both, and heavier wherever the campus makes its own power | Air permitting counsel who can see aggregation risk before it is a violation |
| Qualifying data center sales-tax exemption | In force; certification and audit at year five | Texas Comptroller of Public Accounts | Both metros | Tax and incentives counsel who can survive certification review |
A head of legal at a Houston independent power producer described the division of labor to us in terms worth borrowing. On his side of the table, the campus is a counterparty with a credit profile and a curtailment posture; on the operator’s side, the same campus is a building with a delivery date. Both descriptions are complete and neither is sufficient, and the two legal departments that have to transact with each other are staffed from cities that do not interview the same people. He put the practical consequence in one line: the negotiation goes slowly whenever one side has to phone a law firm to understand the other side’s document.
A general counsel at a Dallas-headquartered colocation operator made the complementary point about sequencing. Her department had been sized for volume — a lease book, a construction program, a procurement pipeline — and the change since 2025 was not that the volume fell but that a single low-frequency workstream became the one that decided whether any of the volume mattered. She was explicit that the answer was not to convert the department: it was to add one seat that could hold a regulated position and to stop pretending the utility relationship was a commercial account.
- Q1 Which of the three gates has moved your date on your last two projects? If the honest answer is interconnection and your department is entirely delivery — you are recruiting in the wrong metro.
- Q2 Will this campus hold generation behind the meter, or take everything from the grid? If it makes its own power and nobody in the department reads air authorizations — the environmental exposure is unowned.
- Q3 Is your outside-counsel panel free to act against the utility if it has to be? If the waiver conversation has not happened — you have a capability on paper you may not be able to use.
- Q4 Can at least two shortlisted lawyers show a record rather than an interest — a docket, a hearing, a closed financing, a campus? If every CV is adjacent — budget a supervised ramp and keep outside counsel on the critical path meanwhile.
- → All four clear? Brief one city for the seat and buy the other bench deliberately, rather than discovering it late.
What a realistic timetable looks like
The typical in-house search runs 4 to 7 months from brief to start date. Completion runs at 93 percent across the 22 in-house searches Sartori has closed in Dallas, and at the same rate across the 19 closed in Houston. The variance is not in the sourcing. In Dallas the market is dense enough that a delivery shortlist assembles quickly and the close is fast, at a 12-working-day median between offer and acceptance. In Houston the shortlist is smaller, the candidates are being approached by employers outside the state, and the median gap is 13 working days. What actually consumes the calendar in both cities is the two or three weeks at the start in which a company decides which of its gates it is really hiring against — and the companies that skip that conversation are the ones that run the search twice.
For the service view of either book, the Dallas in-house desk and the Houston in-house desk set out how we brief, map and close these seats. Companies building a legal function from nothing rather than adding to one should start with the first general counsel guide instead, because the scoping question there comes before the geography one.
Common questions about hiring legal counsel for Texas data centers
Where should a company hire data center legal counsel in Texas — Dallas or Houston?
Hire against the instrument on your critical path: of the 22 in-house searches Sartori closed in Dallas over three years, 14 were delivery seats and only three were energy. Dallas holds the delivery bench — site, lease, construction, procurement. Houston holds the energy, projects and infrastructure-finance bench, and the seats that closed on our Houston book were frequently filled for employers whose campus was somewhere else in the state entirely. The practical test is simple. If the thing that can stop your project this quarter is a city council vote or a construction claim, that is a Dallas hire. If it is an ERCOT study milestone, a large-load tariff, a curtailment protocol or a security package, that is a Houston hire — and both benches now sit on the same project.
What does an in-house data center legal seat pay in the Dallas market?
Disclosed Dallas bands ran from about $155,000 to $300,000 across public postings between November 2025 and August 2026. A global interconnection operator advertised a Dallas litigation counsel seat at $155,000–$233,000. A colocation operator posted a senior director, corporate counsel for energy at $240,000–$260,000 and a senior director, corporate counsel for its investment-fund work at $270,000–$300,000. An AI-cloud operator advertised an associate general counsel for real estate development and data centers at $260,000–$320,000, on a posting that listed San Francisco while describing national campus work including Texas. What is missing from that set matters as much as what is in it: no comparable Houston in-house data-center band surfaced on a public posting in the same window, because Houston’s equivalent capability is largely still sold by the hour rather than carried on a company payroll.
Does a Houston energy lawyer transfer onto a Dallas campus seat?
A Houston energy lawyer needs months of supervised ramp on the Dallas delivery instruments, not a pay adjustment: the offer itself closes in a 12 working-day median. That median is Sartori’s Dallas in-house telemetry, so the negotiation is rarely what goes wrong. A lawyer who has spent a career on PURA, ERCOT protocols and offtake will read a large-load tariff faster than anyone a Dallas operator can hire locally, and will still need supervision on a Lewisville special-use permit, a Fort Worth water-loading study or a construction-claim file. The reverse is worse. Texas counties generally cannot zone at all under Local Government Code Chapter 231, so a Dallas practitioner whose instinct is a conditional-use permit has no instrument to reach for on unincorporated land, and none at all inside the City of Houston.
What changed for Texas large-load interconnection in 2025 and 2026?
Three things: Senate Bill 6 took effect 20 June 2025, Batch Zero was approved 18 June 2026, and a statewide audit paused it 3 August 2026. The bill wrote large-load interconnection standards, co-location review and curtailment protocols into the Public Utility Regulatory Act for loads of 75 MW and above. The Public Utility Commission of Texas then approved ERCOT’s cluster-study process, grouping qualifying requests into a single system-wide study rather than running them in series. Then the Governor of Texas directed a comprehensive verification and audit of every data center moving through the interconnection process before any project advances, and ERCOT postponed its Batch Zero classifications the same day by market notice. A connection request that used to be a commercial conversation with a utility is now a regulated proceeding with filings, fees, security and a state audit attached.
Can our outside-counsel panel act for us if it also acts for the utility?
Bloomberg Law reported in March 2026 that Texas firms advising three transmission and distribution utilities were simultaneously taking data-center work, some requiring advance conflict waivers. Ask for the waiver position before you brief, not after. The utilities named in that reporting were Oncor, CenterPoint Energy and Texas-New Mexico Power, and several firms had begun building ethical walls around the two books. Interconnection, cost allocation and siting are exactly the questions on which a transmission and distribution utility and a large-load customer can sit on opposite sides. For a general counsel this is a sequencing problem more than an ethics problem: the deepest ERCOT and PUCT relationships in the state often sit at firms with utility histories, so the waiver conversation belongs at the start of the engagement. It is also the strongest argument for holding at least one energy-regulatory seat in-house rather than renting all of it.
Do we actually need a zoning lawyer for a Texas data center site?
Only inside a Dallas-ring municipality: Texas counties hold no zoning power under Local Government Code Chapter 231, and the City of Houston has none either. Houston regulates development instead through Chapter 42 platting, Chapter 19 floodplain rules and private deed restrictions, which is a different legal skill rather than a lighter version of the same one. Inside the Dallas-Fort Worth municipalities, zoning is very much the instrument: MultiState counted at least 100 local Texas ordinances considered since 1 July 2025, and Fort Worth’s council initiated a moratorium process on 11 August 2026 after its Zoning Commission split 7–4 on a package of data-center amendments a month earlier. On unincorporated land the live instruments are floodplain, drainage, septic and, where a county has overreached, vested-rights litigation.
Statutes, utility disclosures, agency records and property panels.
Texas statutes and Public Utility Commission rules, ERCOT working-group material, quarterly utility disclosures from Oncor and CenterPoint, city and county land-use records, TCEQ and Comptroller filings, and commercial-property research panels.
Sources & further reading
40 references- Sartori & Partners — Dallas and Houston Legal Talent Research Programme (500 structured interviews in Dallas and 275 in Houston; approximately 20,000 lawyers mapped in Dallas and 11,000 in Houston; quarterly surveys since 2019; in-house mandate telemetry) sartoriglobal.com ↗
- Texas Legislature — Senate Bill 6, 89th Legislature (effective 20 June 2025), enrolled text capitol.texas.gov ↗
- Texas Legislature — SB 6 bill history, 89th Regular Session capitol.texas.gov ↗
- Public Utility Commission of Texas — Project 58481, large-load interconnection standards (draft 16 TAC 25.194) interchange.puc.texas.gov ↗
- Greenberg Traurig — Texas Senate Bill 6 update: proposed interconnection standards (17 March 2026) gtlaw.com ↗
- Public Utility Commission of Texas — 16 TAC 25.205, co-located net metering, adopted 26 March 2026 ftp.puc.texas.gov ↗
- ERCOT — Large Load Integration (Batch Zero, PGRR145, 75 MW path) ercot.com ↗
- ERCOT — Market Notice M-A080326-01, postponement of Batch Zero classifications (3 August 2026) ercot.com ↗
- Utility Dive — Texas approves initial large-load interconnection process against a 438 GW queue (22 June 2026) utilitydive.com ↗
- Utility Dive — PUCT approves ride-through rules for data centers, NOGRR282 (13 July 2026) utilitydive.com ↗
- Office of the Texas Governor — directive for a comprehensive data center audit (3 August 2026) gov.texas.gov ↗
- Oncor — 2025 results and 2026-2030 base capital plan (26 February 2026) oncor.com ↗
- Oncor — third-quarter 2025 results, interconnection queue and customer collateral (5 November 2025) oncor.com ↗
- Rigzone — CenterPoint targets 8 GW of data center load, Q1 2026 report (26 April 2026) rigzone.com ↗
- Utility Dive — CenterPoint Energy Batch Zero submissions and Houston large-load outlook (28 July 2026) utilitydive.com ↗
- Latitude Media — ERCOT large-load queue quadruples in a year (3 December 2025) latitudemedia.com ↗
- ERCOT Large Load Working Group — large-load interconnection status summary (data as of 18 June 2026) ercotqueue.com ↗
- CBRE — North America Data Center Trends H2 2025 (25 February 2026) cbre.com ↗
- CBRE — Dallas-Fort Worth inventory and availability, H2 2025 press table (26 February 2026) cbre.com ↗
- CBRE — Houston data center market profile, H1 2025 (8 September 2025) cbre.com ↗
- City of Fort Worth — data centers: zoning package, water, incentives and moratorium calendar fortworthtexas.gov ↗
- MultiState — the local fight over data centers: a Texas case study (19 August 2026) multistate.us ↗
- The Texas Tribune — Hill County rescinds its data center moratorium (5 June 2026) texastribune.org ↗
- Texas Legislature — SB 2038 summary, release from extraterritorial jurisdiction (effective 1 September 2023) capitol.texas.gov ↗
- Texas Local Government Code Chapter 231 — county zoning authority statutes.capitol.texas.gov ↗
- City of Houston Planning and Development — development regulations and no-zoning letter houstontx.gov ↗
- Harris County Engineer — floodplain management and development permits oce.harriscountytx.gov ↗
- Harris County Flood Control District — role, history and Atlas 14 criteria hcfcd.org ↗
- TCEQ — 30 TAC 106.511 permit by rule for portable and standby engines tceq.texas.gov ↗
- TCEQ — standard permit for electric generating units, including the natural-gas-engine variant tceq.texas.gov ↗
- TCEQ — TPDES construction general permit TXR150000 tceq.texas.gov ↗
- Floodlight — Texas data centers and minor-source air authorizations (9 July 2026) floodlightnews.org ↗
- University of Houston Law Center — Data in the Air: Texas permitting and the contested-case path (7 July 2026) law.uh.edu ↗
- Texas Comptroller of Public Accounts — qualifying data center sales-tax exemption comptroller.texas.gov ↗
- U.S. Army Corps of Engineers, Galveston District — nationwide and general permits swg.usace.army.mil ↗
- U.S. Army Corps of Engineers, Fort Worth District — regulatory program swf.usace.army.mil ↗
- Bloomberg Law — data center rush poses conflicts for law firms with energy ties (17 March 2026) news.bloomberglaw.com ↗
- Texas Lawyer — data center work off to the races as firms expect more in 2026 (18 December 2025) law.com ↗
- Sartori & Partners — In-House Counsel Recruiting in Dallas ↗
- Sartori & Partners — In-House Counsel Recruiting in Houston ↗
Statutes and adopted rules are the Texas Legislature and the Public Utility Commission of Texas; the draft interconnection rule is covered by a law firm's published note on it. Load, capital and collateral figures are Oncor and CenterPoint quarterly disclosures. Interconnection totals are ERCOT working-group material and the Governor's office. Colocation inventory, absorption and vacancy are CBRE research panels, which count a different universe from the utility filings. Environmental, floodplain, tax and land-use citations are the issuing agency or city. Compensation figures are ceilings published on individual employer job postings. The Sartori research program covers interview cohorts in both metros, quarterly surveys running since 2019 and in-house mandate telemetry.
For the adjacent client-system view, see the infrastructure and project-finance vertical and the Dallas in-house counsel salary map. Lawyers weighing a move onto one of these benches will find the in-house transition playbook more useful than this page.
Next steps on the Texas map.
The service pages carry the city-by-city detail; the guides carry the scoping questions that come before a geography is chosen.
In-House Counsel Recruiting in Dallas
The service view of the Dallas book — how we brief, map and close corporate legal seats across the metro, campus work included.
See the Dallas in-house deskIn-House Counsel Recruiting in Houston
The Houston equivalent, where the transferable bench is energy, projects and infrastructure finance rather than delivery.
See the Houston in-house deskHiring Your First General Counsel
For companies building a legal function rather than adding to one — scope, reporting line, budget and the first ninety days.
Read the first-GC guideA quiet conversation
Staffing a Texas campus — or weighing a move onto one of these benches?
We run in-house search desks in both Dallas and Houston, and we are just as willing to tell a company it is briefing the wrong city as to open the search. Confidential, no obligation.