Contracts
Review Master Service Agreements (MSAs): Engineering and environmental consulting firms contracting with Regional Water Planning Groups or the state must review "Change in Law" provisions.
- Ensure your contracts acknowledge that "Guidance Principles" are now fixed for five-year terms.
- If you are mid-contract during a Plan adoption year, ensure you have a mechanism to adjust scope/pricing if the new five-year rules impose stricter modeling or data standards.
Hiring/Training
Regulatory Affairs Training: Retrain government relations staff and external lobbyists. They must stop monitoring for the standard Government Code §2001.039 four-year sunset reviews for these specific rules. Resources must be reallocated to surge during the specific pre-Plan adoption windows.
Reporting & Record-Keeping
Internal Docketing: Update your corporate legal docket. Remove any automatic reminders set for standard agency rule expirations regarding TWDB planning rules. Replace them with a trigger set for 18 months prior to the next scheduled State Water Plan adoption.
Fees & Costs
Budgeting for Advocacy: There are no new statutory fees. However, trade associations and large corporations should restructure their lobbying budgets. Instead of a flat annual spend on water rule monitoring, budget for a significant increase in technical and legal consulting costs every fifth year to address the consolidated rulemaking window.
