Pin down party by party

• When the old effort stalled, which exact route was being pursued: facility corridor, area CCN, dual certification, or sale?
• Why did Waco need to sign — CCN 10039 territory, sewer 20010, plat approval, or relationship?
• Why did Ross need to sign — did the mapped corridor actually cross Ross 11268, or was it a courtesy no-protest?
• Why did Chalk Bluff matter — overlap, the emergency meter/interconnect, sale talks, or politics?

Verify the numbers

• 45 meters plus about 5 more: who calculated it, and what is the limiting factor — well gpm, storage, treatment, pressure, or TCEQ design capacity?
• $20K–$25K "up to par for the CCN" vs the separate $30K–$40K filter number: same job or two jobs?
• 18–24 months: which filing path and what experience is that based on?
• Operator at about $800/month: who is it, what license class, and what does the work actually involve?

Unblock the engineers

• Zeke said engineers stalled waiting on entity, ownership, contacts, address, financials, and financial responsibility.
• What entity name was on the old work — Halbert Water Supply Corporation, Heritage Water Supply LLC, or something else?
• What exactly do the engineers need from us to restart, and who is the engineering contact today?

Zeke's own role

• He said he prefers owning/managing the system if the community can wait — is he willing to be the named operator or manager?
• Would he pursue the license path (short class/test, learn under the existing operator)?
• Can he be the named owner of the document chase with a date?

In hand, verified

• Live map facts: Waco 10039 definite; Ross 47.5-acre parcel overlap; Chalk Bluff F200 line 239 ft away; no issued HH CCN (re-checked 2026-06-10).
• Operating PWS TX1550143, roughly 45-46 connections, groundwater.
• Current PUC CCN form (Dec 2025) and a packet checklist that matches it.
• Verified clocks: 30-day completeness, 30-day notice window, no 180-day CCN deadline.
• Verified lever: 50-acre expedited release, TWC 13.254(a-1), 60-day clock, McLennan qualifies.
• Recovered Water Engineers proposed CCN map (Exhibit B).
• Simulation blocker map from the June 9 MiroFish run.

Recovered, not yet proof

• The proposed CCN boundary exhibit proves prior work product, not authority.
• "All-but-signed" Waco/Ross/Chalk posture is still oral.
• Zeke's draft CCN application: existence reported, files not produced.
• Operator path (Zeke/Streamline) and engineer path (Ray Young) are named, not signed.

Missing and gating

• Signed Waco agreement (Bro. Dadi lead) — the #1 pull.
• Ross letter and Chalk Bluff no-protest on the exact corridor.
• Exact F200 corridor GIS/shapefile.
• Engineer scope: is $20K-$25K the same job as $30K-$40K?
• Meter list and water books feeding the five-year FMT pro forma.
• Entity decision, officers, and who signs.
• STGCD status + SB 2440 groundwater certification for the plat lane.
• Wastewater statement for phase one.

1 · "Halbert WSC" is a vehicle we control

The checklist says it is inactive on SOS; the transcript first called it "Hubbard"; a June 13 web search found zero public footprint anywhere. A WSC is member-owned by law — reviving a forfeited shell can resurrect old members, board, and debts, and Heritage may not control it.

Bite: a whole officer/bylaws packet built around a shell that cannot be used at filing. Check: SOSDirect / Comptroller entity lookup before any field is filled.

2 · A WSC gives Heritage control

Chapter 67 WSCs are member-controlled, one-member-one-vote, with strict 501(c)(12) private-benefit limits. The design intent is that the developer does not control it. Treating "Heritage WSC" as the control path may be backwards.

Bite: 12 months to a CCN held by an entity leadership cannot steer, or that trips private-benefit rules. Check: one counsel question — WSC vs. investor-owned/LLC CCN for control.

3 · December 2026 is a fixed deadline we must beat

The exact trigger, dollar amount, and amendability of the homestead purchase agreement (G1.4) have never been read into the record. The whole urgency — and the September release decision rule — is calibrated against an unverified constraint.

Bite: sprinting against a deadline that is softer (amendable) or harder (worse exposure) than assumed. Check: read the actual contract clause — arguably ahead of the WSC packet.

4 · Waco is friendly-but-slow, not adverse

The only Waco document is an unsigned 2021 draft that may be expired, with Ray's comments flagging real problems. The release fallback (TWC 13.254(a-1)) has an unresolved linchpin: does Heritage's existing PWS service defeat the "not receiving service" element?

Bite: a protest turns the 60-day release clock into a multi-year contested case, and the BATNA may not qualify. Check: get the 13.254 element answered before September, not at the decision point.

5 · Solving water unlocks platting

The tract sits inside Waco's sewer CCN too; McLennan rules require a wastewater plan to plat; SB 2440 makes groundwater-availability certification mandatory; and the Trinity well faces a data-center drawdown risk with STGCD status unverified.

Bite: water CCN filed, then subdivision stalls on wastewater capacity or a groundwater cert that cannot be supported. Check: confirm with the county what phase-one platting actually requires.

6 · The system stays stable while we negotiate

Two single points of failure keep 46 live connections compliant: one contracted operator (name unverified) and an emergency-only Chalk Bluff interconnect that "may be at risk of shutoff" — and we are about to ask Chalk Bluff for a favor while drinking their water.

Bite: a lapsed operator makes us non-compliant exactly when proving capability; soured talks cut the emergency supply. Check: confirm the operator contract is durable; read the interconnect terms first.

7 · "Filing-ready" means "subdivision-ready"

A CCN filing is not a grant; the 30-day completeness clock is not a decision clock; lenders and title need actual service authority, not a pending application. The "filing-readiness sprint" language quietly invites the confusion.

Bite: the December math breaks if "we filed" gets treated as "we can convey lots." Check: hold the distinction explicitly in every status update.

The meta-risk · transcript creep

Load-bearing numbers — $600K build, $225K–$250K Chalk offer, $800/mo operator, 46 connections, 90-day transfer, the "Halbert" name — entered via transcripts and memory, were tagged "verify," and have propagated until they feel like fact.

Bite: decisions anchored on figures nobody confirmed. Check: honor the tracker's "Do Not Use Yet As Proof" list under deadline pressure.

June 10 verification pass

• 30-day administrative-completeness clock confirmed; deficiency cures run about 30 days per round.
• No 180-day statutory CCN decision deadline exists; that figure belongs to the STM sale path (16 TAC 24.239(o)).
• 50-acre expedited release (TWC 13.254(a-1)) confirmed available in McLennan: 60-day statutory clock, compensation by appraisal, and Waco has no facilities at the tract.
• SB 2440 groundwater-availability certification (TCEQ-20982) is mandatory for groundwater-supplied plats since January 2024.
• Live PUC layers re-checked: Waco 10039 unchanged; still no Heritage/Homestead/Halbert record.
• December 2025 CCN form confirmed current; the filing checklist matches it.

June 10 proposed CCN map

• Water Engineers Exhibit B is now in the dashboard pack as PDF and PNG.
• The map shows a proposed Homestead Heritage water CCN boundary and proposed Chalk Bluff WSC CCN boundary.
• It confirms useful prior work product, not an issued HH CCN.
• Message lead: Bro. Dadi Lev-Cochav may have the signed Waco agreement.

June 6 internal meeting

• Lead path shifted toward Heritage-controlled WSC / facilities + 200 feet or facilities-only.
• Sale stays as fallback, but counsel must answer whether filing a Heritage CCN hurts sale optionality.
• Zeke is the document source: maps, agreements, draft application, engineer notes.
• The room specifically wants the actual CCN application if it was already started.
• Zane/Alex own the Phase A1 / road-frontage subdivision test.
• If local-control prep and sale prep can both continue without conflict, keep both lanes alive until the proof decides.
• Tuesday is the next paperwork checkpoint.

Chalk Bluff latest minutes

• May 12 minutes say Kathleen Dow reported everything looked good with Waco CCN and the next Waco update should be in July.
• May 12 minutes show CBWSC approved hydraulic mapping for $66,200.
• April minutes said that mapping/pressure-plane/hydraulic work should take about 20 weeks.
• April minutes also show CBWSC voted to move forward with a dual CCN map with Ross/RWSC.
• These support the "get actual maps and letters" lane; the signed Waco/Ross/Chalk package still has to be produced.

Project stance

• Keep Phase A1 moving in parallel with the WSC/F200 path.
• Ask Waco for three choices: serve Phase A1, consent/no-protest to our narrow route, or refuse in writing.
• Ask Zane whether a two/three-lot road-frontage filing can move faster than the full subdivision route.
• Ask Alex for the phase survey and road-frontage map needed to test that route.
• Any plat relying on groundwater now needs the SB 2440 groundwater-availability certification (TCEQ-20982 by a PE/PG) or a county waiver — fold STGCD status into the Zane/Alex packet.
• Use Isaac's deadline facts as schedule pressure, not as the reason to sell the whole water system.

Questions for Isaac / Zane / Alex

• What exact deadline or carrying cost is driving the sale clock?
• What proof would justify a 30-day pause before sale talks move forward?
• Has anyone asked Waco the narrow Phase A1 question in writing?
• What exact Waco document would let the parcel plat, title, and close?
• Can Phase A1 or nearby lots be filed two or three at a time with road frontage?
• Would repeated small filings create future subdivision problems?

Waco

City of Waco water CCN 10039 is the clear mapped gate. The planned F200 path needs Waco handled by consent, no-protest, dual certification, amendment, release, or another counsel-approved mechanism.

Ross

Ross WSC 11268 overlaps seven selected Halbert/Gholson/Homestead Gristmill parcels. The exact proposed F200 corridor must be checked before saying Ross is optional.

Chalk Bluff

Chalk Bluff WSC 10019 is an F200 facility-line CCN nearby. Current selected-parcel check does not show overlap, but Chalk Bluff still matters if the plan uses its facilities, interconnect, service, sale, or contract rights.

Chapter 67 WSC

• Nonprofit water/sewer corporation under Texas Water Code Chapter 67.
• Board-run, with members/customers and published rates/conditions.
• Fits the water job: own/operate facilities, apply for CCN, collect membership/tap/capital fees, keep local control.
• Still needs PUC-recognized authority before retail-billing conveyed lots.

Generic co-op

• Useful as plain English only if everyone means "member-owned utility."
• Texas Utilities Code Chapter 161 is for electric cooperatives, not a water CCN path.
• No evidence it reduces PUC/TCEQ/FMT burden for water.
• Creates avoidable confusion unless counsel says a different entity is better.

Why it stays warm

• The meeting raised a Lacy Lakeview mayor/data-center conversation tied to Brazos River access.
• Annexation could potentially bring sewer, road responsibility, and regional infrastructure capacity.
• Keeping the water system may make Heritage more valuable in that conversation, not less.
• It may become useful later if Heritage wants a larger service-area, city/incorporation, or regional utility strategy.

What must be written before it leads

• They identify the exact annexation/corridor route.
• They say who provides retail water and sewer after annexation, and under what authority.
• They identify every Waco/PUC/TCEQ action still needed.
• They put cost, capacity, rates, timing, taxes, road obligations, and required Heritage concessions in writing.
• They say whether the Heritage water system would be bought, contracted, connected, or left alone.

Useful leads from the call

• Engineers may be waiting on entity, ownership, contact, address, financials, and financial responsibility.
• Current system is reported around 45 meters, with about 5 more before capacity pressure.
• Zeke reports an engineer-related $20K-$25K upgrade estimate, but the item and trigger are not identified.
• Carl-source notes separately mention a filter-system upgrade around $30K-$40K.
• Zeke said he favors owning/managing the system if timing allows.
• Selling water to Chalk Bluff does not solve the separate sewer issue.

Claims to correct or prove

• "All three must consent" is not proven as a blanket legal rule.
• No PUC rule found creates a hard 45- or 50-meter CCN limit.
• $20K-$25K is not a budget until the engineer writes the scope, reason, and timing.
• Keep the $20K-$25K capacity/CCN estimate separate from the $30K-$40K filter estimate until the engineer confirms they are the same job.
• 18-24 months is an experience estimate, not a rule.
• Signed/draft agreements must be produced before relying on them.

Upgrade questions for Carl / Zeke

1. What exact component is this: filter, storage tanks, pressure, pump, treatment, controls, meters, backflow, sampling, or mapping?
2. Who gave the number and when?
3. What written engineer email, memo, quote, or plan/spec note supports it?
4. What problem does it fix: TCEQ compliance, PUC FMT proof, pressure, storage, peak demand, or added meters?

Why it matters

1. If required for TCEQ compliance, it may be urgent operations work.
2. If required for PUC CCN proof, it may belong in a capital improvement plan.
3. If required only for extra meters, it may not block a Phase A1/Waco written-answer sprint.
4. If it is just a rough capacity tweak, it should not drive a sale decision.

Use this in the room

• "The number is not the answer. The scope is the answer."
• "If this is TCEQ compliance, say so. If it is PUC FMT proof, say so. If it is capacity for new meters, say so."
• "We can test the Heritage-controlled path only if the engineer gives the item, reason, cost, and trigger."
• "Selling now because of an undefined upgrade is a bad decision."

Documents to pull

• Engineer email or memo behind the $20K-$25K number.
• Operator notes, TCEQ reports, sampling results, and any filtration/treatment deficiency.
• Storage, pump, pressure, well, permit, and daily/peak-demand numbers.
• As-builts, meter list, facility map, and old CCN map package.

Use our live numbers

• Start with reported 45 meters, then verify from the meter list.
• Put only the new taps Heritage would actually serve into Year 1-5; keep Waco/Phase A1 separate unless counsel says those lots belong in the Heritage filing.
• Separate operator cost, testing, electricity, chemicals, repairs, insurance, admin, and professional fees.

Backer math

• Minimum backstop equals the 5-year projected O&M shortfall.
• If required plant work exceeds $100K, add a signed funding commitment or loan approval for that work.
• Backer can cover temporary cash shortages only if the backer passes a leverage test.

Ask today

• Can the existing water-operation books be separated from church/property books?
• What is the real current rate and tap/connection fee?
• Are the $20K-$25K and $30K-$40K items under the $100K trigger alone or part of a bigger required CIP?

Dates we cannot skip verified 6/10

• Administrative completeness is determined within 30 calendar days of file stamp — this is the real "30-day clock."
• There is no 180-day statutory deadline for a CCN decision; TWC 13.246 contains none. The "180 days" people remember is the STM sale-path approval-to-proceed window (16 TAC 24.239(o)).
• If PUC says the packet is incomplete, the fix window is usually about 30 days per round.
• After notice goes out, people have 30 days to object or intervene; 25+ acre landowner opt-outs are effective without further hearing — and here that class is internal to Heritage.
• Newspaper notice runs two weeks, and proof of notice has its own deadlines.
• After a final CCN order, the map change must be recorded in county records by day 31.
• Sale/STM clocks for comparison: 120-day runway, at least 30-day intervention, and the 180-day closing window.
• Release lever: a 13.254(a-1) expedited-release petition must be decided within 60 days of completeness.

What is mostly on us

• There is no required waiting period before filing. We can move as fast as the packet is complete.
• There is no guaranteed PUC order date after filing.
• PUC speed depends on clean maps, clean finances, clean notice, and no protest.
• TCEQ only becomes a major timing problem if real construction, treatment, or system changes must be approved first.

First-30-day proof package the simulation demands

1. Service-area authority map packet: Waco/Chalk/Ross evidence, no-HH-CCN check, plain-English boundary memo.
2. Waco response-trigger package: one formal written request offering structured options — serve, consent/no-protest, release, refuse in writing, or negotiate a service-area agreement.
3. Chalk Bluff fallback proof package: binding-enough term sheet with coverage, rates, capacity, timing, and what stays subject to approvals.
4. County/title/lender acceptance template: ask what proof format they need before locking language.
5. Counsel/engineer/operator alignment memo: authority path, feasibility path, compliance path, cost allocation, open questions.

Timeline gates from the run

• Day 0-30: build the proof packet, trigger Waco's written posture, validate the fallback, get proof-format expectations.
• Day 30-60: usable Waco path → move to agreement; refusal → pivot with the written reason preserved; silence → treat as an active blocker, not waiting.
• Day 60-120: convert the chosen path into counsel-reviewed documents, FMT proof, and county-facing evidence. Do not spend heavily on construction design before the authority chain survives review.
• After day 120: execution mode only if authority proof is in writing; otherwise manage as 12-18 months with 18-24+ as the risk case.

Leadership / Carl

1. Has anyone already pursued the narrow F200 route, or only a broader route?
2. Has Waco ever been asked the narrow Isaac/Phase A1 question in writing?
3. Where are the signed Waco agreement, drafted Chalk Bluff agreement, Ross correspondence, and old maps?
4. Who at Waco can give a written posture?
5. What relationship exists with Ross, and who is trusted there?
6. What exact document does county/title/lender need before lots can move?
7. Can we get water-specific books today: current cash, AR, AP, debt, net assets, rates, fees, and O&M?

Isaac / Zane / Alex

1. What exact deadline or carrying cost is creating sale pressure?
2. What Waco answer or plat proof would change that timing concern?
3. Can Phase A1 or a smaller set of lots move by road-frontage/minor-plat route?
4. What road width, drainage, cul-de-sac, or county/Waco condition blocks it?
5. Would repeated small filings create future subdivision problems?

Zeke / engineer / counsel

1. Why exactly do Waco, Ross, and Chalk Bluff each need to sign?
2. What map was used for that conclusion?
3. What limits the next meters: well, storage, treatment, pressure, permit, or rules?
4. What exactly is the $20K-$25K upgrade, and is it the same as the $30K-$40K filter item?
5. Is the upgrade required before filing, before PUC approval, before adding meters, or only for long-term capacity?
6. What entity name and financial proof are you waiting on?
7. Does filing a Heritage WSC CCN application make a later Chalk Bluff sale/transfer harder?
8. Does Heritage's own PWS service on the tract defeat the "actually receiving water or sewer service" element of a 13.254(a-1) release petition?
9. If Waco stalls past September, how should a release petition and the Heritage CCN filing be sequenced so the corridor and the authority arrive together?