Sale Path Vs F200 Timing Date prepared: 2026-06-06 Purpose: meeting-ready timing comparison for the Bro Carl / Isaac French discussion. Status: internal prep, not legal advice. Use this to frame questions for counsel and leadership. Bottom Line Do not compare “fast sale” against “slow F200” as if both are proven. Compare the actual clocks: - Sale/transfer has real PUC STM timing: a 120-day notice/application runway, at least a 30-day intervention period, possible hearing/SOAH risk, 30-day status updates after approval, and a 180-day closing window after approval. - The Chalk Bluff sale estimate in local notes is not one number: 2-3 months only as an optimistic assumption, 4 months heard by one participant, 6-9 months from Brother Carl / Zeke, and longer if STM, Waco/Ross, Docket 56800, TCEQ, capacity, maps, or protests block it. - The Heritage-controlled F200 path is not automatically two years. It is 6-12 months if narrow, pre-consented/no-protest, and no-deficiency; 18-24 months if contested, broad, serial, or deficient. - The 30-day sprint does not finish either path. It answers whether selling produces lawful retail water faster than the narrow/no-protest F200 path. Hard Rule / Form Clocks ------------------------------------------------------------------------ Path Real clock Source point ----------------------- ------------------------ ----------------------- Sale / STM File application and 16 TAC 24.239(b). give notice no later than 120 days before the effective date of the sale/transfer/merger. Sale / STM Intervention period must 16 TAC 24.239(d). be at least 30 days unless shortened for good cause. Sale / STM If no public hearing is 16 TAC 24.239(k). required, transaction may complete at the end of the 120-day period or after notice from the commission that no hearing will be required. Sale / STM After approval to 16 TAC 24.239(l). proceed, transferee gives written status updates within 30 days and every 30 days after until complete. Sale / STM Approval to proceed 16 TAC 24.239(o). expires after 180 days unless extended. CCN / F200 Deficient application PUC CCN Obtain or Amend cure period is usually form, Dec. 2025 30 days from ALJ order. instructions. CCN / F200 Once sufficient, PUC CCN Obtain or Amend applicant gives notice; form, Dec. 2025 hearing requests or instructions. commission hearing decision can send it to SOAH. CCN / F200 No single fixed issuance PUC CCN Obtain or Amend date appears in the form and Chapter 24 form; schedule depends rules. on sufficiency, notice, RFIs, opt-outs, protests, maps, FMT, TCEQ/operator/engineer proof, and agreements. ------------------------------------------------------------------------ Meeting Comparison ---------------------------------------------------------------------------- Question Chalk Bluff sale path Heritage-controlled F200 path ----------------------- ------------------------ --------------------------- What can 30 days prove? Whether Chalk Bluff has Whether exact corridor map, a written retail-water Waco/Ross written posture, path: exact STM/PUC/TCEQ entity/FMT proof, steps, Waco/Ross operator/engineer scope, handling if any, service and county/title/lender authority, capacity, proof look workable. rates/fees, and closing terms. Fast case 2-3 months only if 6-12 months if narrow, authority/service proof pre-consented/no-protest, is already clean and and no-deficiency. Waco/PUC/TCEQ do not block. Local oral estimate 4 months heard by one Zeke/Carl/Drive notes often participant; 6-9 months say about two years for from Brother Carl / Zeke own-system path. notes. Bad case Longer than 6-9 months 18-24 months if contested, if STM, Waco/Ross, broad, deficient, or Docket 56800, TCEQ serial; 24+ months if ownership/engineering, hearing/engineering/FMT capacity, map issues pile up. deficiencies, or protests delay it. Decision rule Sale only wins on time F200 remains worth testing if Chalk Bluff can put if Waco/Ross posture and the faster FMT/engineer proof can be lawful-retail-water path built without a fight. in writing. ---------------------------------------------------------------------------- Sentence For The Room “Phase A1 is a Waco question. The sale timing comparison is time to lawful retail water: if Chalk Bluff buys the system, when can it lawfully provide and bill retail water, and what PUC, TCEQ, Waco/Ross, capacity, map, or protest issues can still block that date?” If We Run F200: Clear Timeline The 30-day sprint is not the finish line. It is the filter that tells us whether the clean 10-12 month F200 track is real enough to keep ahead of a sale. -------------------------------------------------------------------------------- Time Plain-English What we do What slows it down step ----------------- ----------------- ------------------- ------------------------ Days 1-30 1. Find the proof Build the exact Maps are missing, F200 map, pull the upgrade scope is vague, meter list/books, or nobody has the pin down the water-system records. upgrade scope, and list what Waco/Ross need to answer. Months 2-3 2. Build the Prepare the Finance proof, operator, application WSC/applicant info, engineer, filtration packet rates, five-year answer, or parcel data numbers, is weak. backer/reserve proof, operator letter, engineer letter, and landowner list. Month 3 3. Get Waco/Ross Ask for a written Waco or Ross fight it, answer yes, no-protest, or will not answer, or want refusal on the a different route. exact corridor. This is the main timing gate. Months 4-5 4. File a Submit the PUC CCN PUC says the filing is complete packet application with missing items. Each maps, finances, deficiency round can engineer/operator cost about 30 days. proof, tariff, TCEQ items, and numbered attachments. Months 6-8 5. Get through Send required Notice is wrong, people notice and notices, answer PUC object, a utility questions Staff questions, protests, or Staff asks handle landowner for major changes. opt-outs, and fix map or tariff comments. Months 9-12 6. Finish the Resolve final Staff There is a hearing, order comments, finalize unresolved protest, or the map/tariff, required clear TCEQ or treatment/construction engineering work is not settled. questions, and target an uncontested order. -------------------------------------------------------------------------------- Government Clocks Vs Our Speed ---------------------------------------------------------------------------------- Item Timeline type Actual clock Plain-English meaning ----------------- ---------------------- ---------------------- ------------------ Before filing Mostly our speed No fixed government We can move as waiting period before fast as the map, filing finances, operator, engineer, tariff, TCEQ items, and Waco/Ross posture are ready. Filing early with missing pieces just creates delays. PUC completeness Government/ALJ No fixed approval PUC first checks check schedule date; if incomplete, whether the packet cure date is usually is complete enough 30 days from ALJ order to move. If not, we fix it and lose time. Notice after PUC Government-enforced Hearing/intervention This is a real says the packet deadline is 30 days waiting period. is ready from mailing or People get time to publication unless object. changed Landowner opt-out Government/statutory Qualifying 25+ acre A narrow corridor landowners can opt out lowers the chance during notice / before of opt-outs and day 30 after notice map cleanup. Proof of notice Government-enforced Notice affidavit due The notice within 30 days; paperwork has newspaper notice runs deadlines. Missing two weeks; publication them slips the proof due within 30 schedule. days after last publication Final PUC Government/PUC No single fixed PUC sets the processing schedule issuance date schedule after notice. Staff questions, objections, maps, tariff, and final recommendation control the finish. TCEQ plan review Government technical TCEQ review is If no major review if construction required before construction is or major system construction or needed, this can changes are involved significant PWS run beside the PUC changes case. If filtration/plant work is required first, it becomes a major delay. County recording Government-enforced Record in county This happens after after order cleanup records not later than the order. It is day 31 after final CCN not the main order delay. Sale / STM Government-enforced 120-day sale/transfer Sale has comparison runway, at least government clocks 30-day intervention, too. It is only and 180-day closing faster if Chalk window after approval Bluff has a clean written service path. ---------------------------------------------------------------------------------- Biggest Time Chunks -------------------------------------------------------------------------------------- Time chunk Clean case Bad case Why it matters ------------------------------- ----------------- ------------------ ----------------- Waco/Ross posture 30-90 days before 6-12+ months if it Existing CCN filing becomes a fight position is the biggest legal timing gate. FMT/finance/engineer/operator 60-120 days Repeated 30-day PUC will not packet before filing deficiency cycles carry a weak applicant packet just because the need is real. PUC sufficiency, notice, and 4-7 months after 9-18+ months if This is where the Staff review filing protested or official clock deficient lives after the packet is filed. TCEQ/upgrade scope Parallel if scope Adds months if The $20K-$25K / is narrow filtration/plant $30K-$40K upgrade work must be question must be designed, funded, pinned down. or approved first Hearing/SOAH risk Avoided Adds 6-12+ months This is what turns the clean F200 track into the two-year story. -------------------------------------------------------------------------------------- Bottom line: the fastest credible F200 case is roughly 10-12 months after green light, but only if Month 3 produces Waco/Ross posture and the packet is clean. The practical decision in 30 days is whether the biggest time chunks are under control or whether sale remains the faster lawful-retail-water path. Sources - PUC STM form: https://ftp.puc.texas.gov/public/puct-info/industry/water/forms/STM_Form.pdf - 16 TAC 24.239: https://www.puc.texas.gov/agency/rulesnlaws/subrules/water/subchh/24.239/Default.aspx - 16 TAC 24.235 notice requirements: https://ftp.puc.texas.gov/public/puct-info/agency/rulesnlaws/subrules/water/subchH/24.235/24.235.pdf - PUC CCN Obtain or Amend form: https://ftp.puc.texas.gov/public/puct-info/industry/water/forms/CCN_Form_PFA.pdf - TCEQ public water system plan review: https://www.tceq.texas.gov/drinkingwater/planrev.html - Local estimate sources: 00-command-center/wiki.md, 00-command-center/critical-path.md, 00-command-center/agent-board.md, 04-outputs/meeting-notes/2026-06-02-brother-carl-water-strategy-extract.md, 04-outputs/decision-packets/2026-06-02-updated-master-solution.md, 04-outputs/legal-regulatory/2026-06-03-phase-one-wsc-waco-approved-path.md.