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Signed Into Law
Signed May 29, 2025Effective 2025-05-29
HB2692

Regular Session

Relating to the San Antonio River Authority.

Government Affairs & Regulatory Compliance Analysis

HB2692: Government Affairs Overview

HB2692 codifies and strengthens the San Antonio River Authority’s (SARA) regulatory, taxing, and enforcement powers across Bexar, Wilson, Karnes, and Goliad Counties. While framed as a statutory revision, this law grants SARA immediate authority to regulate river-adjacent franchises, designate flood plains beyond FEMA standards, and enforce pollution controls with civil penalties. Real estate developers, industrial dischargers, and river-based tourism operators face the most significant operational exposure.

Rep. Ryan Guillen·House Bill·Regular Session

Moderate
Medium Cost
Effective:2025-05-29

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HB2692
Relating to the San Antonio River Authority.
Moderate Urgency
Heavily Contested
House Vote104 - 32
YEA
NAY
76% in favor136 voting
Senate Vote31 - 0
YEA
100% in favor31 voting
32
Total Opposition Votes
Cost Impact
Medium
Effective
2025-05-29
Enforcing Agencies
Parks and Wildlife DepartmentSan Antonio River AuthorityTexas Commission on Environmenta...
Primary Author: Rep. Ryan Guillen
89th Texas Legislature
jdkey.com
01

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

  • Effective Date: May 29, 2025 (Law is currently active).
  • Compliance Deadline: Immediate. Franchise operators must align accounting practices now. Developers must verify SARA flood plain designations before breaking ground.
  • Agency Rulemaking: The SARA Board must adopt bylaws for procurement and policies for nonprofit fundraising. Critical Warning: New ordinances regarding pollution and public safety take effect 5 days after their second weekly publication in local newspapers. There is no central digital registry requirement; you must monitor print media.

Immediate Action Plan

  • 1. Audit Franchise Terms: Immediately review river operation contracts for term limits and rate control clauses; prepare for SARA to assert rate-setting authority.
  • 2. Monitor Pollution Districts: Assign staff to watch Board agendas for the creation of "Pollution Control Districts." You have a strict 30-day window to file a lawsuit contesting inclusion in such a district.
  • 3. Verify Eminent Domain: Before negotiating land sales, Legal Counsel must verify if SARA filed the required expiration exemption letter with the Comptroller. If they failed to do so, they may lack condemnation power.
  • 4. Update Bid Monitoring: Adjust procurement workflows to monitor local newspapers (San Antonio Express-News and county papers) for bid notices, as digital-only notice is not the standard.

Operational Changes Required

Contracts

  • Franchise Agreements: Review all agreements for operations on navigable canals/waterways. Terms exceeding 50 years are now statutorily invalid. If your contract is silent on rate regulation, be advised that SARA now has the statutory right to regulate your fees and tolls.
  • Wholesale Water: You cannot execute a wholesale water supply contract with SARA until a public notice has been published. Build a 3-week buffer into closing schedules to accommodate this statutory delay.
  • Construction Bids: Contracts are awarded to the "lowest and best" bidder. If you are not the low bidder, you must provide documentation justifying why your bid offers superior value to survive a challenge.

Hiring/Training

  • Accounting Staff: Finance teams for franchise holders must be trained to maintain "uniform and adequate analytic accounting systems." SARA has the right to demand these specific reports to justify your rates.
  • Board Interaction: If your business interacts with SARA Directors, verify they have filed their required $5,000 bond and sworn statement. Acts by unbonded officers may be legally voidable.

Reporting & Record-Keeping

  • Franchise Financials: Maintain segregated accounts for all river-derived revenue. This data will be your primary defense if SARA attempts to aggressively regulate your consumer rates.
  • Pollution Control: If a "Pollution Control District" is established over your property, you must document compliance with specific discharge rules to avoid civil penalties.

Fees & Costs

  • Ad Valorem Tax: The Authority is capped at 2 cents per $100 valuation, subject to voter approval.
  • Ordinance Filing: Expect standard county recording fees for accessing new Authority ordinances.
  • Litigation Risk: SARA is authorized to recover litigation costs in civil suits regarding rule violations.

Strategic Ambiguities & Considerations

  • "Thermal" and "Artificial" Pollution: The law allows SARA to regulate these types of pollution without defining them. Industrial facilities discharging cooling water or aesthetic runoff are in a "regulatory gray zone" until the Board adopts specific technical definitions.
  • Flood Plain Designation: SARA may "study, designate, and regulate flood plains." This authority likely exceeds FEMA maps. Land that is federally insurable may still be restricted by SARA ordinance, potentially stranding assets.
  • "Reasonable" Penalties: The statute permits "reasonable and commensurate" civil penalties. Until tested in court, the upper limit of these fines is discretionary and subjective.

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Information presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.

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Legislative Timeline

This bill's path through the Texas Legislature

Filed
Feb 12, 2025
Passed House
Apr 30, 2025
Passed Senate
May 16, 2025
Signed
May 29, 2025
Effective
May 29, 2025
TopicsSan Antonio River AuthoritySan Antonio River Canal & Conservancy DistrictSpecial Districts & AuthoritiesSpecial Districts & Authorities--river AuthoritiesStatutory Revision
03

House Authors

Rep. Ryan GuillenRepublican · Primary Author

Senate Sponsors

Sen. Charles PerryRepublican · Primary Sponsor
Cosponsors (1)

Bill Text(with markup)

Showing first 50k characters.

View bill text in multiple formats on Texas Legislature website

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Quick Reference

Frequently Asked Questions

Common questions about HB2692

Q

What does Texas HB2692 do?

HB2692 codifies and strengthens the San Antonio River Authority’s (SARA) regulatory, taxing, and enforcement powers across Bexar, Wilson, Karnes, and Goliad Counties. While framed as a statutory revision, this law grants SARA immediate authority to regulate river-adjacent franchises, designate flood plains beyond FEMA standards, and enforce pollution controls with civil penalties. Real estate developers, industrial dischargers, and river-based tourism operators face the most significant operational exposure.

Q

Who authored HB2692?

HB2692 was authored by Texas Representative Ryan Guillen during the Regular Session.

Q

When was HB2692 signed into law?

HB2692 was signed into law by Governor Greg Abbott on May 29, 2025.

Q

Which agencies enforce HB2692?

HB2692 is enforced by Parks and Wildlife Department (Fish preservation rules), San Antonio River Authority and Texas Commission on Environmental Quality (Supervisory role).

Q

How significant are the changes in HB2692?

The regulatory priority for HB2692 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of HB2692?

The cost impact of HB2692 is estimated as "medium". This may vary based on industry and implementation requirements.

Q

What topics does HB2692 address?

HB2692 addresses topics including san antonio river authority, san antonio river canal & conservancy district, special districts & authorities, special districts & authorities--river authorities and statutory revision.

Q

What are the key dates for HB2692?

Key dates for HB2692: Effective date is 2025-05-29. Rulemaking: Adopt bylaws for the publication of notice to bidders and related procurement procedures (Sec. 8513.0318). (Immediate/Ongoing); Develop policy regarding fund-raising activities of affiliated nonprofit organizations (Sec. 8513.0330). (Immediate/Ongoing). Consult with legal counsel regarding applicability.

Q

What are the penalties under HB2692?

HB2692 establishes the following penalties: civil/administrative penalty of Commensurate penalties as provided by Section 49.004, Water Code for Violation of Authority rules/ordinances or franchise conditions (Sec. 8513.0325, 8513.0402).. Consult with legal counsel for specific applicability to your situation.

Need Strategic Guidance on This Legislation?

JD Key Consulting is an Austin, Texas-based government affairs firm led by James Dickey, former Chairman of the Republican Party of Texas. We specialize in Texas regulatory compliance and legislative strategy for data centers, energy, banking, and manufacturing.

Legislative data provided by LegiScanLast updated: January 11, 2026