Relating to the Angelina and Neches River Authority, following recommendations of the Sunset Advisory Commission; specifying grounds for the removal of a member of the board of directors.
ModeratePlan for compliance
Low Cost
Effective:2025-06-20
Enforcing Agencies
Angelina and Neches River Authority • Office of the Governor (Texas) • Office of the Attorney General (Texas)
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date:June 20, 2025 (Law is currently in effect).
Compliance Deadline:December 1, 2025. This is the "Safe Harbor" expiration. Current Directors may vote until this date; afterward, they are barred from voting or deliberating until training requirements are met.
Agency Rulemaking: The ANRA Board must immediately adopt internal policies regarding public testimony and the separation of Board/Staff functions. No external state agency rulemaking is required, but ANRA internal policy generation is critical in Q3 2025.
Immediate Action Plan
Immediate: If you have a pending permit or contract, verify that the current Board President was designated by the Governor, ensuring the agenda is set by the legally authorized chair.
Q3 2025: Stakeholders should review ANRA's upcoming meeting agendas for the adoption of new public testimony rules and prepare compliance teams to navigate new registration procedures.
November 2025: Conduct a "Quorum Check." Verify which Directors have completed training. If key votes on your business are scheduled for December, ensure the Directors supporting your position are legally eligible to vote.
Ongoing: Vendors and contractors must direct operational inquiries to the General Manager, not Board members, to respect the new statutory separation of powers and avoid procedural delays.
Operational Changes Required
Contracts
Signatory Authority: The law mandates a strict separation between policy-making (Board) and management (General Manager). Ensure operational contracts and vendor agreements are negotiated with and executed by the General Manager, not the Board, to align with the new statutory division of duties.
Political Risk: The Governor now designates the Board President (previously a Board-elected position). Long-term strategic agreements should be viewed through the lens of direct gubernatorial oversight rather than local Board autonomy.
Hiring/Training
Mandatory Director Training: The General Manager must create a training manual covering audits, ethics, and open government laws.
Voting Lockout: Directors must complete this training to vote. HR/Legal departments within ANRA must track this meticulously to prevent invalid votes on permits or contracts.
Attendance: Directors absent from >50% of meetings face mandatory removal.
Reporting & Record-Keeping
Complaint Tracking: The Authority must implement a formal tracking system for all complaints. You must notify parties of the complaint status "periodically" until disposition.
Annual Acknowledgments: Directors must sign an annual statement acknowledging receipt and review of the training manual. These records must be audit-ready to prove the validity of any Board vote.
Fees & Costs
No Statutory Fee Increases: The bill does not authorize new fees.
Operational Costs: Administrative costs will be incurred to develop training manuals and complaint tracking systems, but these are internal to the Authority.
Strategic Ambiguities & Considerations
"Periodically": The statute requires the Authority to notify complaint parties of status "periodically" but does not define the interval. Stakeholders involved in disputes should demand a defined reporting schedule (e.g., monthly) to prevent the Authority from defaulting to vague, infrequent updates.
"Reasonable Opportunity": The Board must allow the public to speak on jurisdictional issues. The definition of "reasonable" is left to the Board. Expect new Rules of Order regarding time limits and speaker registration; failure to comply with these yet-to-be-written rules could result in being barred from testimony.
"Disability": Grounds for removal include "illness or disability." The statute lacks a medical definition or adjudication process, potentially leaving removal proceedings open to political interpretation or litigation.
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First established in 1935 as the Sabine-Neches Conservation District, the Angelina and Neches River Authority (ANRA) primarily provides water and wastewater services to rural communities. ANRA, which is not subject to abolishment under the Texas Sunset Act, acquires, rehabilitates, and operates these systems at the wholesale and retail level. ANRA also monitors water quality in the Neches River basin, issues permits for on-site sewage facilities, and operates a composting facility. Overall, the Sunset Advisory Commission identified good governance standards and best practices that would strengthen ANRA's operations. C.S.H.B. 1520 seeks to implement those standards and practices for ANRA and provide for its next sunset review in 2037.
CRIMINAL JUSTICE IMPACT
It is the committee's opinion that this bill does not expressly create a criminal offense, increase the punishment for an existing criminal offense or category of offenses, or change the eligibility of a person for community supervision, parole, or mandatory supervision.
RULEMAKING AUTHORITY
It is the committee's opinion that this bill does not expressly grant any additional rulemaking authority to a state officer, department, agency, or institution.
ANALYSIS
C.S.H.B. 1520 amends the Special District Local Laws Code to set the next review of the Angelina and Neches River Authority (ANRA) under the Texas Sunset Act to be conducted during the 2036-2037 review cycle.
C.S.H.B. 1520 revises provisions governing ANRA to implement across-the-board Sunset Advisory Commission policy recommendations relating to the following:
·board member training;
·gubernatorial designation of the presiding officer of ANRA's board of directors;
·specific grounds for removal of a board member;
·public testimony before the board;
·separation of the board's policy-making responsibilities and the staff's management responsibilities; and
·maintenance of a complaint system.
The bill provides for the transition to the new training requirements for current board members.
C.S.H.B. 1520 decreases from six years to four years the length of a board member's term and provides for the transition to the decreased term length. The bill requires the board to employ a general manager.
C.S.H.B. 1520 establishes that all applicable requirements relating to the following have been fulfilled and accomplished with respect to the bill:
·the legal notice of intention to introduce;
·governor action;
·Texas Commission on Environmental Quality recommendations; and
·the state constitution and laws and legislative rules and procedures.
EFFECTIVE DATE
September 1, 2025.
COMPARISON OF INTRODUCED AND SUBSTITUTE
While C.S.H.B. 1520 may differ from the introduced in minor or nonsubstantive ways, the following summarizes the substantial differences between the introduced and committee substitute versions of the bill.
The substitute includes provisions that were not in the introduced decreasing from six years to four years the length of a board member's term and providing for the transition to the decreased term length.
Honorable Cody Harris, Chair, House Committee on Natural Resources
FROM:
Jerry McGinty, Director, Legislative Budget Board
IN RE:
HB1520 by Kitzman (Relating to the Angelina and Neches River Authority, following recommendations of the Sunset Advisory Commission; specifying grounds for the removal of a member of the board of directors.), As Introduced
No significant fiscal implication to the State is anticipated.
It is assumed that any costs associated with the bill could be absorbed using existing resources.
Local Government Impact
No significant fiscal implication to units of local government is anticipated.
Source Agencies: b > td >
116 Sunset Advisory Commission
LBB Staff: b > td >
JMc, TUf, MMF
Related Legislation
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HB1520 mandates an immediate governance overhaul of the Angelina and Neches River Authority (ANRA), strictly separating Board policy duties from staff management and enforcing new Director training protocols under threat of voting disenfranchisement. Entities with active permits, contracts, or disputes with ANRA must monitor Board quorum stability, as non-compliant Directors will be legally barred from voting on business matters after December 1, 2025. Implementation Timeline Effective Date: June 20, 2025 (Law is currently in effect).
Q
Who authored HB1520?
HB1520 was authored by Texas Representative Stan Kitzman during the Regular Session.
Q
When was HB1520 signed into law?
HB1520 was signed into law by Governor Greg Abbott on June 20, 2025.
Q
Which agencies enforce HB1520?
HB1520 is enforced by Angelina and Neches River Authority, Office of the Governor (Texas) and Office of the Attorney General (Texas).
Q
How urgent is compliance with HB1520?
The compliance urgency for HB1520 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of HB1520?
The cost impact of HB1520 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does HB1520 address?
HB1520 addresses topics including angelina & neches river authority, governor, special districts & authorities, special districts & authorities--river authorities and sunset.
Legislative data provided by LegiScanLast updated: November 25, 2025
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