HB 144 Pole Management Plan: What Every Texas Utility Must File Before January 2027

Every electric utility, electric cooperative, and municipally owned utility in Texas has to file a distribution pole management and inspection plan with the Public Utility Commission of Texas by January 1, 2027. That is the deadline set by House Bill 144, passed by the 89th Texas Legislature in 2025 and now implemented by the PUCT's new rulemaking under Project No. 59431.

From today, that deadline is roughly six months out. The rule specifies exactly what the plan must contain, how it must be formatted for filing, and how annual compliance updates must be structured going forward. Every entity that owns or operates a distribution asset in Texas is subject to the requirement — no de minimis exception for small co-ops or small municipal utilities.

This article decodes what an HB 144 pole management plan must include, section by section. The requirements are anchored to the PUCT's proposed rule at 16 Texas Administrative Code §25.63, published in the Texas Register on March 27, 2026, and to the underlying statute at Texas Utilities Code §38.103 as enacted by HB 144. Where the rule requires interpretation, we explain what the plain reading appears to require and identify where the ambiguity sits.

Why HB 144 Exists

The Smokehouse Creek Fire of February 2024 destroyed more than 1.058 million acres of the Texas Panhandle, killing three people and roughly 15,000 head of cattle. It is the largest wildfire in Texas history. The Texas House Select Investigative Committee on the Panhandle Wildfires, chaired by Representative Ken King, released a 48-page report in May 2024 tracing the fire to a decayed utility pole that had been flagged by an Osmose Utility Services inspection in January 2024 for “priority one replacement.” The replacement was never completed before the high winds of late February that year.

The 89th Texas Legislature responded in the 2025 regular session. House Bill 144, sponsored by Representative King and Senator Charles Schwertner, added Section 38.103 to Subchapter E of Chapter 38 of the Texas Utilities Code. The statute took effect on September 1, 2025, and set the January 1, 2027 initial-plan filing deadline. Companion legislation Senate Bill 1789 added PURA Section 38.006, which directs the PUCT to adopt statewide structural integrity standards for transmission and distribution poles.

The PUCT contracted Guidehouse, Inc. under Contract No. 473-25-00019 to provide expert consulting services for rulemaking, plan review, and structural integrity standards development. The contract is capped at $3,500,000. Every plan filed will pass through commission staff supported by that engagement. The commission's implementing rule, 16 TAC §25.63, was published for public comment on March 27, 2026 under Project No. 59431, and adoption of the final rule is imminent as of this writing.

Who Must File An HB 144 Pole Plan

The rule applies to each electric utility, municipally owned utility, and electric cooperative that owns or operates a distribution asset in this state. There are no carve-outs by size or service territory. Investor-owned utilities regulated under ERCOT, entities operating outside ERCOT, small electric cooperatives, and municipal utilities of every scale all fall within scope.

If an entity owns or operates a distribution asset in Texas, the entity has a filing obligation. Entities that outsource distribution operations to a third-party service provider are still the responsible filer — the plan is filed by the asset owner, not the operator.

When The Plan Is Due And What Format Works

The initial plan is due by January 1, 2027, filed in a control number designated by commission staff for this purpose. The commission has not yet published the assigned control number as of this writing; entities should watch the PUCT Interchange for the assigned number and start preparing filings against the current proposed rule.

Subsequent filings follow a compressed early cadence and then transition to an eight-year cycle. By January 1, 2028, each entity must file either an affidavit that the initial plan complies with the transmission and distribution pole structural integrity standards adopted under PURA §38.006 or a revised plan that does comply. After that 2028 milestone, the schedule diverges by entity class: electric utilities file revised plans every eight years starting January 1, 2032; municipally owned utilities every eight years starting January 1, 2034; electric cooperatives every eight years starting January 1, 2036.

The staggered eight-year cycles reflect the differential regulatory posture of investor-owned utilities, munis, and co-ops under Texas Utilities Code Chapter 41. IOUs face the earliest revision milestone; co-ops receive an additional four-year window before their first revised plan is due.

The rule specifies the filing format. The plan must be filed as a searchable PDF document AND in Microsoft Excel format for all included tables, with formulas intact. This is not a stylistic preference. Non-searchable PDFs and Excel files with formulas stripped are non-compliant with the rule as written. Commission staff review will require both formats to function properly.

The Seven Elements Every HB 144 Plan Must Include

The heart of the rule is the required content of the plan itself. HB 144 lists five statutory categories at Texas Utilities Code §38.103(b). The PUCT's implementing rule at 16 TAC §25.63(c)(2) disaggregates those categories into seven distinct required elements. Each is decoded below.

1. Scope and objectives

The plan must contain a statement of scope and objectives for ensuring public safety through effective management, inspection, maintenance, and repair of distribution poles. The rule names four operational functions — management, inspection, maintenance, and repair — and ties them to a single measurable outcome: public safety. Scope statements that address only inspection, or that omit repair, fall short of the plain text.

2. Roles and responsibilities

The plan must describe the roles and responsibilities of individuals responsible for overseeing and executing the plan. The rule uses “individuals” rather than “departments,” suggesting the commission expects named accountability rather than functional descriptions. Governance clarity — who signs off, who executes, who audits — is the operative standard.

3. Personnel training and certification

The plan must describe the entity's processes for training and certifying personnel, including third-party vendors, who inspect distribution poles. The explicit inclusion of third-party vendors is material. Entities that outsource pole inspection to firms like Osmose Utility Services or Katapult must document how those vendors are trained and certified — not only their own W-2 personnel. The rule closes a gap that had allowed liability delegation without oversight documentation.

4. Inspection and remedial action timeline

The plan must include an estimated timeline for completing inspections and remedial action required for any distribution pole identified as unreliable, unsafe, or needing repair. The timeline must be consistent with the transmission and distribution pole structural integrity standards adopted by the commission under PURA §38.006.

This requirement creates a forward reference to the SB 1789 structural integrity standards. As of this writing, those standards have not yet been finalized. Entities filing initial plans in advance of the §38.006 adoption should structure timelines against best-available industry practice — Rural Utilities Service Bulletin 1730B-121 pole inspection guidance, National Electrical Safety Code inspection criteria — and then be prepared to file the compliance affidavit or revised plan by January 1, 2028 once §38.006 standards are adopted.

5. Landowner complaint documentation and response

The plan must describe the entity's processes for documenting and responding to a report or complaint made by a landowner regarding the condition or repair of a distribution pole. This element is the direct implementation of the accountability recommendation from the House Panhandle Wildfires committee report, which found that landowner concerns about deteriorating infrastructure had been documented internally but never actioned.

The rule does not prescribe a specific format for landowner complaint documentation. It does require that both documentation AND response be described. Entities that maintain call-center intake but no traceable resolution record fail the response half of the requirement. Entities that resolve landowner concerns informally with no written record fail the documentation half. The standard is a documented complaint-to-resolution audit trail.

6. Estimated cost of implementation (electric utilities only)

For plans submitted by electric utilities, the plan must include the estimated cost of implementing the plan. This element is expressly limited to electric utilities. Municipally owned utilities and electric cooperatives are not required to submit cost estimates in the initial plan, though the annual compliance update requires actual cost reporting for all entities.

7. Compliance monitoring methods

The plan must describe the entity's methods for monitoring compliance with the plan. This element closes the loop on the six preceding requirements. It answers: how will the entity know that it is doing what its plan says it will do? Self-audit cadence, KPI tracking, escalation triggers, and internal reporting structures all fall within scope.

The seven required elements are cumulative. A plan that satisfies six of the seven is not a compliant plan.

The Efficiency Path For Cooperatives And Municipal Utilities

The proposed rule includes a filing efficiency provision for municipally owned utilities and electric cooperatives. Under 16 TAC §25.63(c)(3), a muni or co-op may fulfill the seven-element content requirements by submitting information required under other law that is substantially similar to the information the rule requires.

Two conditions apply. The entity must clearly identify in its plan which of the seven elements each submitted piece of information is intended to fulfill. The entity must also include a description of why the submitted information is substantially similar to the requirement it is intended to fulfill.

This provision recognizes that many co-ops and munis already produce documentation for RUS reporting, NERC compliance, or municipal audit requirements that overlaps with what HB 144 asks for. The rule permits use of those existing documents — but requires the cross-mapping to be explicit. Vague assertions that “we already file similar information” will not satisfy the substantially similar standard as written. The mapping must be requirement-by-requirement.

The Annual Compliance Update Every Utility Must File

HB 144 creates a recurring reporting obligation on top of the initial plan filing. Every entity with a plan on file must submit an annual compliance update no later than May 1 of each year. The first update follows the initial 2027 filing, meaning the first annual update is due May 1, 2028.

The same format standard applies to the annual update as to the initial plan: searchable PDF and Microsoft Excel with formulas intact. Electric utilities face an additional integration requirement — the annual update must include both the HB 144 pole-related information AND the information required under §25.94 (Report on Infrastructure Improvement and Maintenance). The filing must clearly delineate which information responds to which requirement, so commission staff can distinguish HB 144 content from the parallel §25.94 content within a consolidated filing.

The compliance narrative

The annual update must include a detailed description of the entity's compliance with the plan objectives from Element 1 (scope and objectives). This is a narrative accounting of what the plan promised and what the entity delivered against those promises during the compliance year.

Actual costs

The annual update must include the actual costs of implementing the plan to date, presented both as a total and by compliance year. The by-year breakdown is significant. Entities cannot report a cumulative cost without disaggregating spending across the compliance history. This structure creates a longitudinal cost record commission staff can use to identify entities whose reported spending diverges from their planned budgets.

Pole-level inspection results

The heart of the annual update is the pole-level inspection results reporting requirement. The rule requires four discrete numeric reports:

• Total poles inspected: presented as a raw number AND as a percentage of the entity's total number of distribution poles. Percentage reporting requires the entity to maintain an accurate distribution pole census, which itself is a non-trivial documentation obligation for entities without existing asset management systems.
• Poles needing remediation: the number identified through inspection, accompanied by an indication of the necessary remedial action AND the entity's progress towards completing each action, using the four-status framework — planned, in-progress, delayed, completed — for each pole.
• Poles needing replacement: the number identified, accompanied by the same four-status progress indication toward replacement for each pole.
• Danger poles: the number identified, accompanied by the same four-status progress indication toward making safe AND replacing each pole. The rule uses “making safe” and “replacing” as parallel actions — safing is not a substitute for replacement.

The four-status framework applied at the pole level, not the fleet level, is the rule's highest-friction implementation requirement. Entities that manage pole condition data in spreadsheets or aggregated dashboards will need to migrate to per-pole tracking systems capable of producing status snapshots on demand.

How The PUCT And Guidehouse Will Review Your Plan

Commission staff will review each entity's plan and each annual compliance update to determine compliance with the plan objectives. Staff will issue notice of the determination to the submitting entity AND to the commission.

The dual-notice structure is important. The determination is not just a private communication to the filing entity. It is also delivered to the commission itself. Non-compliance determinations become part of the commission's record and are available to any party in subsequent proceedings.

The underlying statute at Texas Utilities Code §38.103(c) requires the commission to approve, modify, or reject a plan within 180 days of submission. Entities should expect that commission staff review supported by Guidehouse precedes any formal commission action, and that the 180-day statutory window operates from the initial filing date. Entities filing at or near the January 1, 2027 deadline should expect action by approximately June 30, 2027.

How HB 144 And Senate Bill 1789 Work Together

HB 144 sets the plan filing framework. Senate Bill 1789 sets the technical framework the plans have to conform to. The two laws were designed to operate as a matched pair — HB 144 covers procedure (what utilities file and when), and SB 1789 covers substance (what the poles have to actually meet).

SB 1789 added PURA Section 38.006, directing the PUCT to adopt statewide structural integrity standards for transmission and distribution poles, including a uniform serviceability classification system. Those standards were not final as of the March 2026 publication of the HB 144 implementing rule, which is why the rule builds in the January 1, 2028 affidavit-or-revise milestone: initial plans can be filed against the current rule text, then reconciled against the SB 1789 standards once those are adopted.

For deeper context on the SB 1789 side of the pair, see our HB 144 vs SB 1789 comparison, which decodes how the two laws intersect and where each takes precedence.

The Six-Month Path To A Compliant Plan

The January 1, 2027 filing deadline is approximately six months from this writing. Entities that have not yet begun plan development face a compressed preparation window. Six practical steps, in sequence:

1. Assess current documentation posture. Map existing pole management, inspection, training, and complaint documentation against the seven required elements. Identify gaps. Our free HB 144 Readiness Assessment is structured against this framework and produces a per-element gap report in under fifteen minutes.
2. Build the pole census. The annual update requires reporting inspected poles as a percentage of total poles. Entities without an accurate distribution pole count cannot compute the percentage. Census completion is prerequisite to compliance reporting.
3. Establish per-pole tracking. The four-status framework (planned, in-progress, delayed, completed) applied at the individual pole level requires an asset management system or database capable of generating status snapshots. Spreadsheets built for aggregate reporting typically cannot produce the per-pole status detail the rule requires.
4. Document the landowner complaint workflow. Both intake AND response must be documented. Entities relying on informal call-center resolution without written records must build the audit trail before the plan is filed. Third-party tools that produce tamper-evident complaint records with public verification paths — such as AcreSeal's landowner reporting tool — can serve as the documented complaint intake layer.
5. Plan for the January 1, 2028 affidavit-or-revise milestone. The SB 1789 structural integrity standards are being developed by Guidehouse under the PUCT contract. Entities should build flexibility into the initial plan so that the affidavit-or-revise decision in 2028 is a routine administrative filing rather than a scope rebuild.
6. Anticipate the Guidehouse review. Every plan will pass through the Guidehouse contract review. The reviewer will apply consistent standards across all filings. Entities can anticipate the review by structuring plans to make each required element identifiable and evaluable in isolation.

Where Forensic Documentation Meets HB 144 Compliance

The HB 144 rule does not prescribe specific technology. It does prescribe documentation standards that certain technology categories satisfy naturally and others satisfy only with substantial workaround. For three of the seven required elements — training and third-party vendor certification records, inspection and remedial action documentation, and landowner complaint documentation and response — forensic-grade evidence with tamper-evident audit trails is a materially stronger compliance posture than conventional documentation.

AcreSeal produces documentation that satisfies these requirements natively. Every pole inspection, remediation event, and landowner report generates a SHA-256 hash chain anchored to the moment of capture. The verification path is public — commission staff, Guidehouse reviewers, and any party in a subsequent proceeding can independently confirm that a record has not been altered since it was filed. For entities preparing HB 144 initial plans, this eliminates the documentation-integrity questions that consume review cycles.

For related context on HB 144, see our HB 144 fundamentals guide, the HB 144 compliance checklist mapped requirement-by-requirement, and our analysis of the January 2027 filing deadline.