Texas HB 144 Compliance. Mapped element by element.
AcreSeal maps each of the seven plan elements in Sec. 38.103(b) to a feature: three run in the product, three use templates you complete, and the (b)(6) estimated cost is on the roadmap. It also prepares the annual update (Tex. Util. Code §38.103(c)) due each May 1.
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Texas HB 144 (Sec. 38.103), effective September 1, 2025, requires every electric cooperative, investor-owned utility, and municipally owned utility in Texas to submit a distribution pole inspection and management plan to the PUCT. The January 1, 2027 filing date comes from the PUCT's implementing rule, 16 TAC Sec. 25.63, adopted July 30, 2026 and effective August 19, 2026; the statute itself sets no filing date. Under Tex. Util. Code Sec. 38.103(b), the plan must cover seven required elements — scope and objectives, roles and responsibilities, training and certification, inspection and remedial-action timelines, landowner complaint handling, estimated cost (electric utilities only), and compliance-monitoring methods — plus an annual update (Tex. Util. Code §38.103(c)) to the PUCT, due not later than May 1 (Sec. 38.103(c)). The PUCT has contracted an outside reviewer for submissions.
Last reviewed October 2026 · Based on Texas Utilities Code Sec. 38.103 and the PUCT's implementing rule, 16 TAC Sec. 25.63.
HB 144 Pole Management Plan — Element by Element
Every required plan element (Tex. Util. Code §38.103(b)) mapped to the AcreSeal feature that addresses it. Coverage status shown for each element.
Beyond these seven plan elements, HB 144 requires one recurring filing: an annual compliance update due not later than May 1 of each year (Tex. Util. Code §38.103(c); 16 TAC §25.63(e), adopted). It also requires reconciliation to the SB 1789 (§38.006) structural-integrity standards once those are adopted.
Coming Soon
Budget projection tools for investor-owned utilities filing under §38.103(b)(6).
Configurable inspection criteria aligned to 16 TAC §25.61, adopted 2026-09-18 under Sec. 38.006.
The export already follows adopted 16 TAC Sec. 25.63: searchable PDF plus Excel with formulas intact. The templates will track the pro forma forms the PUCT finalizes under Project 59996.
Coverage methodology: AcreSeal maps to all seven required plan elements of the statute (Sec. 38.103(b)); 16 TAC §25.63(d) lists eight plan items — landowner-complaint documentation, inspection and remedial timelines, and compliance monitoring fully automated; scope, roles, and training template-assisted; the estimated-cost element (electric utilities only) on the roadmap.
Pole Structural Integrity
Senate Bill 1789 added Tex. Util. Code §38.006 (SB 1789, 89th R.S., 2025): the commission sets standards for the structural integrity of transmission and distribution poles. For electric cooperatives and municipally owned utilities, the key date is February 5, 2027. 16 TAC §25.61 was adopted by the Public Utility Commission of Texas on September 18, 2026 under PUCT Project No. 59432 and takes effect October 8, 2026. It implements the transmission and distribution pole structural integrity standards under PURA §38.006. The annual report is required by §25.61(h), not later than May 1 of each year on a commission-prescribed form. Each municipally owned utility and electric cooperative must adopt the requirements established under subsections (d), (e), (f), and (g) not later than 120 days after the effective date (February 5, 2027), and file an attestation with its first §25.61(h) report, signed by its highest-ranking representative, official, or officer with binding authority. AcreSeal's vegetation module, a separate feature, tracks work orders, before/after photos and growth-rate predictions; it is not part of a §38.006 obligation.
Work Order Tracking
Schedule, assign, and close vegetation work orders with GPS-tagged photo documentation.
Growth Prediction
Linear regression models predict re-growth rates to optimize trim cycles and reduce costs.
Wildfire Risk Zones
Map vegetation density against pole locations to prioritize high-risk corridors.
Not sure where your cooperative stands? Take the free HB 144 Readiness Assessment →
NERC FAC-003-5 Transmission Vegetation Management
Report export not available yetFor utilities managing transmission lines, NERC FAC-003-5 requires documented Transmission Vegetation Management Programs (TVMPs) with inspection schedules, clearance verification, and outage reporting. AcreSeal's vegetation module keeps clearance measurements and before/after photos with each work order. Its NERC FAC-003-5 report export is not available yet.
AcreSeal's vegetation module records clearance measurements by voltage class and flags those below a threshold AcreSeal sets, which is larger than the FAC-003-5 MVCD.
PUCT Review Process
Review-ReadyThe Public Utility Commission of Texas has contracted an outside consulting firm to review and analyze utility pole plans and updates under Sec. 38.103 (PUCT Contract No. 473-25-00019). AcreSeal's compliance exports are designed to produce structured, section-by-section documentation that aligns with regulatory review expectations. See exactly what Sec. 38.103(c) actually requires.
As PUCT publishes specific formatting requirements, AcreSeal will update export templates automatically — included at no additional cost during your subscription.
Rather than static spreadsheets and manual documentation, each complaint record carries a SHA-256 digest over its GPS coordinates, capture time and weather, and an append-only audit chain; a sealed work order adds an Ed25519 signature and an RFC 3161 token. Any record can be checked at acreseal.com/verify without an account.
HB 144 Compliance Timeline
HB 144 signed into law
Governor signs House Bill 144 (89th Legislature, Regular Session)
Implementing rule published for comment
16 TAC Sec. 25.63 published in the Texas Register on March 27, 2026 under PUCT Project No. 59431
Rule adopted
The commission adopts 16 TAC Sec. 25.63 on July 30, 2026, with changes to the published text
Rule takes effect
16 TAC Sec. 25.63 is effective August 19, 2026
Initial plan due
Initial pole management and inspection plan due January 1, 2027 under 16 TAC Sec. 25.63. Sec. 38.103(a) requires the plan; the statute itself sets no filing date.
Affidavit or revised plan due
Due January 1, 2028 under 16 TAC Sec. 25.63
Annual update
Due not later than May 1 of each year under Sec. 38.103(c) — the one recurring filing HB 144 creates
Security Audit Roadmap
AcreSeal will commission an independent third-party security audit of its cryptographic implementation at its first paying engagement, and publish a summary of the findings.
Regulatory Engagement
AcreSeal follows the PUCT's HB 144 rulemaking (Projects 59431, 59432 and 59996) and FEMA Public Assistance guidance, and reads adopted orders rather than proposals. No regulator has endorsed AcreSeal, and none should be inferred.
The Co-Op Manager’s Guide to HB 144 Compliance
An 8-page guide covering everything Texas cooperatives and utilities need to know about HB 144 filing requirements, the annual update, common mistakes, and the compliance timeline through January 2027. Written by a T&D industry expert with 40 years of experience.
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Don’t wait for the deadline.
Start building your HB 144 compliance record today. AcreSeal gives you the plan, the process, and the proof — before PUCT asks for it.
HB 144 — Frequently Asked Questions
Quick answers to the questions Texas utilities ask most about Sec. 38.103.
What is Texas HB 144?
Texas House Bill 144 is a 2025 law codified at Utilities Code Sec. 38.103 that requires every electric cooperative, investor-owned utility, and municipally owned utility in Texas to file a distribution pole inspection and management plan with the Public Utility Commission of Texas by January 1, 2027. Companion legislation SB 1789 directs the PUCT to adopt statewide structural integrity standards.
Who must comply with HB 144?
Every electric cooperative, investor-owned utility, and municipally owned utility in Texas that distributes electric energy to the public, regardless of size.
What is the HB 144 compliance deadline?
January 1, 2027. Every covered utility must submit its initial distribution pole inspection and management plan to the PUCT by that date. After that, the recurring obligation is an annual compliance update due no later than May 1 of each year under Sec. 38.103(c). The rule at 16 TAC Sec. 25.63 — adopted July 30, 2026 under Project No. 59431 and effective August 19, 2026 — adds a January 1, 2028 affidavit-or-revised-plan milestone and revised plans on a staggered eight-year cycle from 2032, 2034 and 2036 by entity class. The enacted statute sets no revision cycle of its own.
What must an HB 144 pole management plan include?
Tex. Util. Code Sec. 38.103(b) requires a pole management plan to cover seven elements:
- Scope and objectives of the plan
- Roles and responsibilities
- Personnel training and certification, including third-party vendors
- Inspection and remedial-action timeline
- Landowner complaint documentation and response
- Estimated cost of implementation (electric utilities only)
- Compliance-monitoring methods
Utilities also file an annual update — the one recurring filing HB 144 creates — due not later than May 1 of each year under Tex. Util. Code Sec. 38.103(c), elaborated by the rule at 16 TAC Sec. 25.63(e).
Who reviews HB 144 submissions?
The PUCT has contracted an outside consulting firm to review and analyze utility plans and updates and recommend findings (PUCT Contract No. 473-25-00019). Under 16 TAC §25.63(g), commission staff file a recommended finding on each entity's compliance for the commission to consider.
What is AcreSeal?
AcreSeal is an add-on evidence layer for Texas HB 144. It keeps tamper-evident, SHA-256 hash-chained records for landowner pole complaints and the annual update exports (Tex. Util. Code §38.103(c)), and complements the work-order, GIS and outage systems a utility already runs. Pole condition checklists are recorded but not yet hash-chained. AcreSeal is founded by Lance Hayes — a former hospital IT leader based in San Antonio, Texas.