HB 144 Compliance Checklist: What Texas Utilities Need Before January 2027
With the January 2027 plan-filing date approaching — a date set by the PUCT's implementing rule, 16 TAC Sec. 25.63(c)(1)(A), adopted July 30, 2026 — every Texas cooperative, municipal utility, and IOU needs a clear picture of where they stand on HB 144 compliance. This checklist maps to the seven required elements of an HB 144 pole management plan — the elements set by Tex. Util. Code Sec. 38.103(b) that each plan must address.
The 9-Point Compliance Checklist
Plan Submission Document
38.103(a)What most utilities have today
No formal plan exists
What PUCT expects
Written plan with scope, objectives, roles submitted to PUCT
Pole Inventory with GPS
38.103(b)(1)What most utilities have today
Partial inventory, many poles untagged
What PUCT expects
Complete asset registry with GPS, tags, circuit ID, install dates
Classification System
38.103(b)(2)What most utilities have today
Informal condition notes
What PUCT expects
Documented methodology: safe, reliable, extreme-weather capable
Complaint Documentation
38.103(b)(3)What most utilities have today
Phone calls and emails
What PUCT expects
Structured intake with timestamps, GPS, photos, lifecycle tracking
Inspection Deadlines
38.103(b)(4)What most utilities have today
Ad-hoc scheduling
What PUCT expects
Per-pole deadlines with SLA tracking and remediation timelines
Implementation Budget
38.103(b)(5)What most utilities have today
No dedicated line item
What PUCT expects
Proposed budget for plan implementation
Remediation Tracking
38.103(c)What most utilities have today
Resolution noted in spreadsheet
What PUCT expects
GPS-verified resolution with photo evidence and inspector ID
Extreme Weather Standards
38.103(d)What most utilities have today
PUCT rulemaking pending
What PUCT expects
Template ready for when criteria are published
Annual Update
38.103(c)What most utilities have today
No annual update prepared
What PUCT expects
Compliance narrative, actual costs by year, per-pole remediation status
Common Gaps We're Seeing
Based on conversations with cooperatives in the San Antonio market, the three most common compliance gaps are:
Complaint Documentation (38.103(b)(3))
Most co-ops handle complaints via phone and email. There's no structured lifecycle, no timestamped evidence, and no way to prove a complaint was received, acknowledged, and resolved.
Annual update format (38.103(c))
No cooperative we've spoken with currently generates per-pole inspection and remediation records at this granularity. This is new — and it is what the annual update, due each May 1, has to be built from.
Inspector Certification Tracking (38.103(b)(2))
Training records exist but aren't linked to specific inspection events, so it is hard to show that the person who inspected pole #4821 was qualified to do so.
Who Reviews the Plans
The PUCT has contracted an outside consulting firm to review plans and updates and recommend findings (PUCT Contract No. 473-25-00019). Under 16 TAC Sec. 25.63(g), commission staff file a report with a recommended finding on each entity's compliance, and the commission decides.
Timeline: What to Do by When
For a month-by-month breakdown of the countdown, see our 2027 filing date article. The short version:
Complete readiness assessment, inventory poles, identify gaps
Select compliance platform, begin data migration, pilot one feeder
Compile the plan document and submit; first annual update (Tex. Util. Code §38.103(c)) follows by May 1
Next Steps
Take the free HB 144 Readiness Assessment — 10 questions, instant gap analysis.
Calculate your compliance ROI — manual vs. automated costs.
Schedule a 20-minute demo — see the platform with your pole data.
By the AcreSeal Team
AcreSeal builds forensic compliance documentation for Texas utility pole management. Records are hash-chained, so a later edit is detectable; anyone holding the file can recompute the digest at acreseal.com/verify. Third-party attested time covers reports a utility has sealed into a work order.