HB 144 Compliance Checklist: What Texas Utilities Need Before January 2027
With less than 9 months until the PUCT deadline, every Texas cooperative, municipal utility, and IOU needs a clear picture of where they stand on HB 144 compliance. This checklist maps directly to the 9 subsections of Sec. 38.103 — the same framework that Guidehouse will use to review your submission.
For a deeper explanation of what HB 144 is and why it exists, see our companion article on HB 144 fundamentals.
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
Monthly PUCT Reporting
38.103(e)What most utilities have today
No monthly reports generated
What PUCT expects
Per-pole pass/fail, safe/reliable/extreme weather, PDF + CSV
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.
Monthly Reporting Format (38.103(e))
No cooperative we've spoken with currently generates per-pole pass/fail reports. This is new — and it's the requirement that drove HB 144's creation.
Inspector Certification Tracking (38.103(b)(2))
Training records exist but aren't linked to specific inspection events. Guidehouse will want to see that the person who inspected pole #4821 was qualified to do so.
The Guidehouse Factor
The PUCT has contracted Guidehouse to review every utility's plan submission. This means your documentation won't just be filed — it will be scrutinized by professional auditors who know what “demonstrable, consistent, and review-ready” looks like. Spreadsheet-based tracking is unlikely to survive this level of review.
For a detailed comparison of spreadsheet-based compliance vs. forensic documentation, see why your spreadsheet won't survive a Guidehouse review.
Timeline: What to Do by When
For a month-by-month breakdown of the 9-month countdown, see our January 2027 deadline article. The short version:
Complete readiness assessment, inventory poles, identify gaps
Select compliance platform, begin data migration, pilot one feeder
Generate first monthly PUCT report, compile plan document, submit
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.
Lance Hayes
Founder, Ectropy Solutions · San Antonio, TX