Texas Wildfire Mitigation Plans and the New Pole Rule

Texas utilities now face two separate obligations from the Public Utility Commission of Texas (PUCT), and they are easy to blur together. The first is the Texas wildfire mitigation plan required by Rule 25.60, which applies only to owners of transmission or distribution facilities in a wildfire risk area. The second is a brand-new pole inspection rule, Rule 25.61, which took effect October 8, 2026 and applies to every utility, municipally owned utility and electric cooperative that operates poles in the state.

For a municipal utility or co-op, the second one carries the nearer date. The rule says munis and co-ops must adopt its inspection, grading, corrective-action and record-keeping requirements not later than 120 days after the effective date. Counting from October 8, 2026, that lands on February 5, 2027.

Here is what each rule asks for, who has filed so far, and what the first contested plan shows about where the work goes.

Who Must File a Texas Wildfire Mitigation Plan

Rule 25.60 covers transmission and distribution owners, including municipally owned utilities and electric cooperatives. The filing duty, though, attaches to owning facilities in a wildfire risk area. That determination can come from the Texas Division of Emergency Management or from the entity itself.

The process runs in a fixed order:

• Notice first. An entity must file a notice of intent at least 60 calendar days before its estimated application date, describing its risk areas, the facilities it owns there and whether it will use the Commission’s optional pro forma plan.
• Then the application. For notices filed after May 1, 2026, the entity may file on the date in its notice unless the Commission schedules a different one.
• An outside reviewer. The application must include an analysis by an independent expert with at least five years of experience in electric utility fire risk mitigation.
• A three-year clock. An approved plan must be refiled for reapproval within three years of approval, or sooner after a material change such as dropping a measure or cutting inspection frequency.

Where the Filings Stand

The filing project for these plans is PUCT Project No. 59402. A Commission Staff memo dated October 8, 2026 counted 15 entities that had filed notices of intent and seven that had filed applications. It also counted 137 entities that had submitted the required acknowledgement of their wildfire risk area determination.

On October 15 the Commission adopted Staff’s recommended schedule for three cooperatives: CoServ Electric and San Bernard Electric Cooperative on October 26, 2026, and Tri-County Electric Cooperative on November 16, 2026. The order says any entity that cannot file on its date must file a revised notice with a new estimate.

That mechanism is already in use. On October 27, Tri-County asked to file on or about December 30, 2026, citing time needed to finish testimony and the independent expert analysis. On October 30, Brazos Electric Power Cooperative filed a notice estimating its application on or after December 29, 2026. Notices from Entergy Texas, CPS Energy, LCRA Transmission Services, Wind Energy Transmission Texas and Cross Texas Transmission also arrived in October, according to the project’s filing list.

There is no single statewide filing deadline. Each entity’s date comes from its own notice or a Commission order, so the docket entry for your own system is the one that counts.

The New Pole Inspection Rule, Rule 25.61

Rule 25.61, “Transmission and Distribution Pole Structural Integrity Standards,” does not depend on wildfire risk. Its main requirements are below. A comprehensive inspection is the rule’s detailed check that goes past a visual look to below-groundline decay, rot and loss of strength.

Requirement	What the rule sets
Distribution wood poles	Comprehensive inspection at least every 8 years in coastal counties, every 10 years elsewhere
Distribution non-wood structures	Comprehensive inspection at least every 12 years
Transmission structures	Annual visual inspection, plus comprehensive inspection every 10 years (wood) or 12 years (non-wood)
After a qualifying event	Visual inspection within 45 days
Grades	Pass, Remediate, Replace or Emergency
Corrective action	Remediate within 6 months (12 with notice), replace within 12 months (24 with notice), make safe within 2 days
Records	Age, ID, design data and full inspection history for each structure’s service life
Reporting	Annual report by May 1

For munis and co-ops, the rule works through adoption. They must adopt the inspection, grading, corrective-action and record-keeping subsections within 120 days, and then file an attestation, signed by their highest-ranking official, with their first annual report after adopting.

The two rules already meet in practice. In the Southwestern Public Service (SPS) case, Commission Staff’s October 28 brief says SPS agreed to amend its wildfire plan to comply with the new Rule 25.61 inspection and maintenance requirements.

What the SPS Plan Shows, and What It Does Not

SPS’s plan, in PUC Docket No. 60042, is a full public example with quantified targets. It is also contested. The case went to the State Office of Administrative Hearings, held a hearing on the merits October 14, and finished reply briefing at the end of October. Staff supports approval; an intervenor challenges SPS’s risk model. No proposal for decision or final order appears on the docket yet.

The plan’s proposed cumulative targets for 2026 through 2028 include:

• Defensible-space clearing around at least 36,000 distribution poles and 600 transmission structures
• 290 weather stations, 68 camera stations and at least 25,000 pole-mounted sensors
• EPSS capability and fault indicators on 232 feeders
• At least 275 miles of overhead distribution rebuilds and 36 miles of targeted undergrounding

Read those carefully. They are proposed targets in a case still under review, not awarded orders. The 36,000-pole figure is vegetation clearing around poles, not pole replacement. And the plan reflects one investor-owned utility’s system, not the needs of a smaller co-op or muni.

What Texas Munis and Co-ops Can Do Now

• Put February 5, 2027 on the calendar as the end of the 120-day Rule 25.61 adoption window, and plan the board or council action that adopts it.
• Check your pole records against subsection (g). The rule asks for an in-service date or age estimate, a unique ID, design data and inspection history for every structure. Our explainer on condition-based pole asset management covers how utilities move from age to condition data.
• Confirm your wildfire risk status. If you own facilities in a designated risk area, your plan timeline runs from your own notice of intent, at least 60 days before you file.
• Line up the independent expert early. Tri-County cited that analysis when it asked for more time; Brazos’s independent expert completed its analysis on September 22, before Brazos filed its notice.
• Watch Docket 60042. The SPS outcome will show what the Commission accepts in a contested plan. Colorado and Minnesota are working through similar questions: see the Colorado rulemaking and Minnesota’s plan order.

Related Reading

• Distribution Pole Asset Management: From Age to Condition
• Colorado Wildfire Mitigation Plan Rules: Comments Nov. 2
• Minnesota Wildfire Mitigation Plans Due Feb. 1, 2027

Rule requirements are from 16 TAC §25.60 and §25.61 as published by the PUCT. Filing counts and dates are from Project No. 59402 filings dated October 8 through October 30, 2026. SPS case status and targets are from PUC Docket No. 60042, checked November 5, 2026. The February 5, 2027 date is our count of 120 days from the rule’s October 8, 2026 effective date.

Texas pole and wildfire rules will keep moving through 2027. The Feeder is our free weekly digest of the regulatory and supply signals that change what utility buyers spec.