Section 38.080, in plain terms
HB 145 added Section 38.080 to the Texas Utilities Code. Electric utilities, city-owned utilities and electric cooperatives that own transmission or distribution lines in a wildfire risk area must file a wildfire mitigation plan with the Public Utility Commission of Texas.
What the plan covers
Risk areas and line inspections, vegetation management, an operations plan to reduce ignitions, procedures for de-energizing lines and disabling reclosers, restoration and community outreach.
The independent analysis
Every plan must include an analysis prepared by an independent expert in fire risk mitigation, filed with the plan.
The review
The PUCT issues an order within 180 days of filing, approving, modifying or rejecting the plan.
The blueprint
In April 2026 the PUCT released a voluntary blueprint and guidelines under Rule 25.60 to give utilities a common structure.
Before you file, and with your filing
Readiness review
We check your draft against Section 38.080 and the PUCT blueprint, flag gaps and weak spots, and give you a clear list of fixes. Delivered in 4 to 6 weeks.
Independent expert analysis
We prepare the independent fire risk mitigation analysis the law requires: an objective read of whether your plan matches your actual risk, and where it falls short.
Small team? That's who we work with.
Most Texas filers are not large utilities with wildfire departments. They are co-ops and city utilities with small teams and a long list of other priorities.
We work alongside your staff, use the plan you already have, and keep the process plain and on schedule.
Field-tested, and independent
Two decades across wildfire, natural resources and federal programs, starting as a wildland firefighter in 2006. At the Bureau of Indian Affairs, Nathan led the analysis that created its Division of Wildfire Management. Native-owned, and independent in every review.
Who has to file a wildfire mitigation plan in Texas?
Electric utilities, municipally owned utilities and electric cooperatives that own transmission or distribution facilities in a wildfire risk area.
What is the independent expert analysis?
Section 38.080 requires each plan to include an analysis of the plan prepared by an independent expert in fire risk mitigation. It is filed with the plan.
Do we have to use the PUCT blueprint?
No. The blueprint is a voluntary starting point. Your plan still needs to fit your own territory, equipment and risk.
How long does PUCT review take?
The commission must issue an order within 180 days after a plan is filed.
Do you work outside Texas?
Yes. We review wildfire mitigation plans in any state. See Expert Reviews →
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