There Is No PUCT Monthly Report Under HB 144
This article originally described a monthly PUCT reporting obligation under Sec. 38.103(e), and a transition to annual filing after 24 compliant months. That was wrong. Those requirements appeared in an earlier draft of HB 144 and were not in the bill that passed. We were reading the draft, not the enacted statute, and we repeated the error across this site for several months. The article below has been rewritten to describe the filing the law actually requires.
HB 144 creates one recurring filing. Texas Utilities Code Sec. 38.103(c), as enacted, says it in a single sentence:
Not later than May 1 of each year, an entity to which this section applies shall submit an update to the commission detailing the entity's compliance with the plan's objectives, the costs of implementing the plan to date, and the results of the entity's inspection of distribution poles, including the number of poles inspected and any remediation or replacement action taken.
That is the whole of the recurring obligation. Sec. 38.103(e), which this article previously cited as the source of a monthly duty, does something else entirely: it lets the commission accept information required under other law where that information is substantially similar. It obliges nobody to report anything.
What the annual update must contain
Compliance with the plan's objectives
A narrative account of what your plan committed to under Element 1 and what you delivered. Commission staff review this to make the determination under Sec. 38.103(d). It cannot be generated from inspection data.
Actual costs of implementing the plan to date
A total and a breakdown by compliance year. Note the asymmetry: co-ops and munis are exempt from the cost estimate in the initial plan (Sec. 38.103(b)(6)), not from reporting actual costs here.
Results of your pole inspections
The number of poles inspected and any remediation or replacement action taken. The adopted rule adds the percentage of your total census, and per-pole progress on remediation, replacement and danger poles.
When it is due
May 1, every year, for every entity with a plan on file. Following the January 1, 2027 plan filing date, the first annual update falls due May 1, 2028. There is no 24-month qualifying period and nothing to apply for.
The part that is genuinely hard
Filing once a year rather than twelve times is less work, but it does not make the requirement easy — and the difficulty is not where this article originally put it. Two of the three elements are things no platform can produce for you. Nobody can write your compliance narrative, and nobody but your finance team knows your actual costs by compliance year. Those are the elements that turn into an April scramble.
The third element has its own trap. The rule at 16 TAC Sec. 25.63(d) asks for progress on each identified action using four statuses — planned, in progress, delayed, completed — applied per pole, not across the fleet. A utility tracking condition in a spreadsheet or an aggregated dashboard cannot produce that from what it has. It also asks for poles inspected as a percentage of your total, which presumes an accurate pole census. That rule was published on March 27, 2026 under PUCT Project No. 59431 and had not been adopted as of this correction, so its detail may change; the statutory requirement in Sec. 38.103(c) does not depend on it.
Why we got this wrong
We built our reading on a version of HB 144 that was amended before passage, and did not re-check it against the enacted text. The monthly-reporting language is specific and plausible enough that it propagated across our guides, our readiness assessment and our product before anyone re-read the statute. If you planned around it because of something we published, we are sorry. The correction is in the software as well as in this article: our platform now generates the annual compliance update, and states on the document itself which statutory elements it has no data for rather than filling them with an estimate.
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.