Texas Municipal Clerks Certification Program
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1 Texas Municipal Clerks Certification Program
2 Campaign Finance and Gift Laws for Municipal Clerks Texas Municipal Clerks Election Law Seminar January 2018 James Tinley Assistant General Counsel Texas Ethics Commission LM Otero/Associated Press 2 Texas Ethics Commission Constitutional state regulatory agency created in 1991 Texas Constitution: Art. III, Sec. 24a Ballot proposition passed Nov. 5, 1991 Offices in Austin 32.4 FTEs (currently budgeted) 8 appointed members 4 by governor, selected from lists by house & senate members (2 each) 2 by house speaker 2 by lt. gov. 3 1
3 Texas Ethics Commission Bi-partisan design 4 members from lists provided by legislators of each major political party 6 votes needed Adopt rules Decide complaints (except dismiss post-formal hrng) Initiate review (complaint) Issue subpoenas Audit a report Initiate civil enforcement Refer to prosecutor 4 Texas Ethics Commission Purpose of Enabling Legislation To protect the constitutional privilege of free suffrage by regulating elections and prohibiting undue influence while also protecting the constitutional right of the governed to apply to their government for the redress of grievances , Gov t Code 5 Texas Ethics Commission Enabling legislation shall be construed to: Control and reduce cost of elections Eliminate opportunities for undue influence Disclose fully information re campaign spending and lobbying Enhance potential for individual participation in electoral and governmental processes Ensure the public s confidence and trust in its government 6 2
4 Four Main Groups of Ethics Laws Campaign Finance & Political Advertising Title 15, Election Code Bribery, Prohibited Gifts, & Honoraria Misuse of Gov t Property Chapters 36 & 39, Penal Code Lobby Law Chapter 305, Gov t Code Revolving Door & Personal Financial Disclosure Chapter 572, Gov t Code 7 How Ethics Laws Work Governmental ethics laws exist to promote confidence in our system of government and a sense of fair play Limit outside influence Require public disclosure Ensure public resources are used for public purposes 8 How Ethics Laws Work Require public disclosure Campaign Finance, Lobby, Personal Finance Campaign finance disclosure deters actual corruption and avoids appearance of corruption (Buckley v. Valeo, 1976) Helps the electorate evaluate candidates Who supports the candidate? How does a candidate spend money? Pol. adv. disclosure 9 3
5 How Ethics Laws Work Publicity is justly commended as a remedy for social and industrial diseases. Sunlight is said to be the best of disinfectants; electric light the most efficient policeman. JUSTICE LOUIS D. BRANDEIS 10 How Ethics Laws Work 2013 Sunset Advisory Commission report Given the few limits state law places on campaign contributions and expenditures, Texas approach to ethics relies on disclosure to shine a light on political financial activity for the public to see and judge 11 THIS IS WHERE YOU COME IN! 12 4
6 Agenda About the Agency Campaign Finance Candidates/officeholders Political Committees Duties of local filing authority Political Advertising Gift Laws Other Disclosures 13 OVERVIEW OF CAMPAIGN FINANCE LAWS 14 Title 15, Election Code Regulates accepting, spending, reporting money in political campaigns Candidates Officeholders Political committees Others making independent (direct campaign) expenditures Civil and criminal penalties for violations Not related to ballot access TEC cannot address ballot access or invalidation of election issues 15 5
7 BNSF tracks in the mist at Carkeek by Steve Voght is licensed under CC BY 2.0 Getting on the ballot and campaign finance are two different tracks 16 Candidate A person who knowingly and willingly takes affirmative action for the purpose of gaining nomination or election to public office... For example: Filing a treasurer appointment Filing an application for a place on the ballot Making a public announcement of definite intent Soliciting or accepting a campaign contribution Elec. Code (1). 17 Campaign Treasurer Appointment (CTA) All candidates for public office must file a CTA. Even if you do not intend to accept or spend any money. including personal funds spent on campaign File Form CTA before accepting or spending money ,
8 EVERY CANDIDATE MUST FILE A CTA 19 Specific-Purpose Committees (SPACs) SPACs must file a campaign treasurer appointment before accepting or spending over $500. If a candidate has an SPAC, both the candidate and the SPAC must file reports. 20 Where to file? Candidates seeking office of a political subdivision file with the secretary of the political subdivision. E.g. Mayor files with City Secretary School Board Trustee files with Board Secretary County Clerk, Sherriff, County Commissioner, etc. file with county 21 7
9 Legislative Update HB 1114 a specific-purpose committee created to support or oppose a measure on the issuance of bonds by a school district shall file reports with the Commission. File original STA locally; File copy of STA and Form SECURITY with TEC, then file SPAC reports with TEC. Codified in ELECTION CODE ; 1 TAC 20.7, Effective September 1, 2015 Deadlines for Candidates Semiannual Reports January 15 th and July 15 th Pre-Election Reports for Opposed Candidates 30 days before an election 8 days before an election 8 days before run-off election 23 Modified Reporting An opposed candidate or SPAC who selects "modified reporting" is not required to file pre-election or runoff reports If filer does not intend to exceed $500 in contributions or expenditures in an election May sign appropriate blank on campaign treasurer appointment form Separate $500 thresholds for each election Still required to file semiannual reports 24 8
10 Modified Reporting Exceeding $500 If "modified filer exceeds $500, must file pre-election reports If exceeded before due date for the "30-day" report, filer must file the pre-election reports If exceeded after the due date for the "30-day" report, must file a report within 48 hours of exceeding $500 Must also file an "8-day" pre-election report by the regular due date for that report 25 Deadlines for Candidates Deadline for reports is 5 P.M. on due date Semiannual reports follow mailbox rule Delivery by mail or other carrier considered filed by postmark date Pre-election & runoff reports Must be received by the due date 26 Final Report A candidate who expects no additional reportable campaign activity may file a Final Report Final Report ends filing obligations as a candidate Local officeholder may have to continue filing if the officeholder has contributions or expenditures over $500 in reporting period Must file a NEW campaign treasurer appointment before accepting any campaign contributions or making any campaign expenditures Includes paying campaign debts, reimbursements 27 9
11 Candidates Duty to file campaign finance reports continues until you file a Final Report. Filing a Final Report terminates your campaign treasurer appointment Can t have any further campaign activity after filing a Final Report. 28 Officeholders Officeholder w/out a CTA on file may only: Accept officeholder contributions. Make officeholder expenditures. 29 Annual Report of Unexpended Funds Former candidate/officeholder that filed a final report AND still retains political funds/assets must file an annual report of unexpended political funds. Must file until no political funds/assets are left
12 Dos and don ts of campaign finance CAMPAIGN FINANCE RESTRICTIONS 31 Corporations and Labor Organizations A corporation or labor organization may not contribute to a candidate or officeholder, or a political committee that contributes to candidates or officeholders Violation is a felony offense If in doubt, call the TEC or seek other consultation 32 Additional Campaign Finance Restrictions No anonymous contributions If accepted, may donate to recognized taxexempt charitable organization Caution: Bake sales, fishbowls, passing the hat No commingling funds No contributions from foreign nationals No contributions at courthouse No cash contributions over $100 No raffles No personal use of contributions 33 11
13 CAMPAIGN FINANCE REPORTS Include money accepted or spent in connection with you campaign 34 Itemization Thresholds Political contributions exceeding $50. Political expenditures exceeding $100. In the aggregate to or from a single person during the reporting period , Elec. Code 35 Total Contributions Maintained Includes, as of the last day of the reporting period, Balance in all political accounts; Value of investments that can be readily converted to cash; Any personal funds deposited into a political account; and Any contributions held in an online fundraising account if the filer exercises control over the account , Ethics Commission Rules 36 12
14 Reporting Political Contributions Monetary contributions E.g. Check or cash Non-monetary (in-kind) contributions Donation of goods or services E.g. signs, office space, food and drinks, supplies, etc. Pledges Promise to contribute Only report if pledge is accepted (3), (4), Elec. Code 37 Reporting Political Expenditures Credit Card Expenditures Campaign or personal cards Unpaid Incurred Obligations An expense you owe but have not yet paid. Payments from Political Funds Including non-political payments Payments from Personal Funds 38 Reporting Expenditures for Processing Fees Multiple expenditures to a single payee for processing political contributions may be combined into a single entry. Date of Expenditure = date of 1 st expenditure made during reporting period. Purpose description must include first & last date of expenditures , Ethics Commission Rules (effective ) 39 13
15 Maintain Records Required to keep records used for a report for at least 2 years from the filing deadline. Examples: Bank statements; Invoices or bills; Copies of contribution checks; Donor information; Receipts for reimbursed expenses; Employee timesheets or payroll records; Written documentation of any cash transactions , Elec. Code; 20.18, Ethics Commission Rules 40 KEEP FILING SEMIANNUAL REPORTS UNTIL YOU FILE A FINAL REPORT 41 Local Filing Authority Duties 42 14
16 Local Filing Authority Duties TEC laws impose no legal duty on local filing authorities to enforce filing requirements TEC laws impose no legal duty on local filing authorities to notify filers of deadlines But other laws outside TEC may apply Some local laws also provide for local enforcement 43 What s My Job? Your primary responsibility under Title 15, Election Code is to accept documents filed by candidates, officeholders, and political committees. Always date-stamp all filings and save postmarks and receipt marks on envelopes. What s My Job? You must also copy and make available all required forms. Ethics Commission Rules You should also make available the appropriate instruction guide for each required form. You may not charge a filing fee. ELEC. CODE
17 What Forms Do I Need to Make Available? 1. FORM CTA 2. FORM ACTA 3. FORM C/OH 4. FORM C/OH-FR 5. FORM C/OH-UC 6. FORM STA What Forms Do I Need to Make Available? 7. FORM ASTA 8. FORM SPAC 9. FORM PAC-DR 10. Instruction Guides for each previously-listed form 11. FORM CFCP and copy of the Fair Campaign Practices Act 12. FORM PFS Code of Fair Campaign Practices Upon receipt of a campaign treasurer appointment, provide the candidate or political committee a blank form of the Code of Fair Campaign Practices and a copy of Chapter 258 of the Election Code. Inform each candidate or political committee that they may subscribe to the code, but subscription is voluntary. Elec. Code
18 Other Resources To Make Available 1. Campaign Finance Guide for Candidates and Officeholders Who File With Local Filing Authorities. 2. Campaign Finance Guide for Political Committees. 3. Campaign Finance Guide for Judicial Candidates and Officeholders. 4. Schedules of Filing Dates. 5. A Guide to Political Advertising: What You Need To Know. 6. A Guide To The Prohibition Against Using Political Subdivision Resources for Political Advertising. Retention Campaign Treasurer Appointment: two years after the date it is terminated. Code of Fair Campaign Practices: same as respective campaign treasurer appointment. Campaign Finance Reports: at least two years after filing. Retention NOTE: If a criminal investigation or proceeding is pending in regard to the election to which title 15 records pertain, you must keep the records until the investigation or proceeding is over. 17
19 Public Access Campaign finance reports and campaign treasurer appointments are public records and must be made available for public inspection during regular business hours. Filing authorities may not require a person examining campaign finance reports to provide any information or identification. Campaign Finance Filing Application TEC released NEW electronic filing software on April 28, 2015 Internet browser-based application Personal computer (PC) or laptop Macs,Tablets Used to file electronically with TEC Local filers can also use to prepare and print reports Must create a login on TEC website Enter data View as PDF Print on paper Sign, Notarize, File Accessing the Electronic Filing Application: Begin at home page Click on File Reports Electronically 18
20 Accessing the Electronic Filing Application: Click on Campaign Finance Filing For more Information: Click on Are you a local filer? Note Instructional Videos For Password Form: Click on Form SECURITY 19
21 To proceed to application: Click on Log In Will need password to continue Click Local Authority 20
22 Electronic Filing of Reports with Local Filing Authority A local filing authority may request the TEC to approve a format for filing reports electronically Section (a), Election Code A home rule city may adopt an ordinance that requires city candidates and officeholders to transmit reports electronically rather than on paper, as long as the ordinance requires the filing authority to make available upon request a paper copy of the report in the same format and paper size as prescribed by the TEC Ethics Advisory Opinion No. 459 Public Access Information in campaign finance reports is expressly public. When providing campaign finance reports in response to public information requests, do not redact any information. See Texas Att y Gen. Op. KP-0151 (2017) For more information about access to public information, contact the Office of the Attorney General Open Records Division. 21
23 Public Access For School Districts with a Student Enrollment of More Than 15,000 and Located Wholly or Partly in a Municipality with a Population of More Than 500,000. Within five days of the filing, post on the school district s website campaign finance reports by: school board trustees, candidates for school board trustee, and specific-purpose committees that support, oppose, or assist a candidate for or member of the board of trustees in a school district. Electronic Posting of Reports Municipalities w/ pop. of 500,000+ must make campaign finance reports by a member of the governing body available on an Internet website maintained by the municipality as soon as practicable after the officer files the report Section (b), Local Gov t Code Local filing authorities may also set their own posting requirements Counties w/ pop. of 1 million+ also must post reports of commissioners court members TEC cannot interpret or enforce these requirements What s Not My Job? DO NOT fill out forms for filers. DO NOT edit, amend, or revise forms. DO NOT misrepresent the date of filing. 22
24 What s Not My Job? You are not expected to be an expert on Title 15. What s Not My Job? If you receive a question and do not know the answer, direct the requestor to the Ethics Commission s website (available at For questions that cannot be answered by the resources on the website, requestors may call the Commission. What s Not My Job? You are not expected to send notices to filers. 23
25 What s Not My Job? You have no responsibility to ensure that required documents are filed. You have no authority to enforce Title 15 or penalize a filer. Termination of Campaign Treasurer Appointment by Local Filing Authority A local filing authority may adopt a process (by ordinance or order) to terminate campaign treasurer appointments for inactive candidates and political committees May terminate if the filer: Has never filed or has ceased to file reports, (In case of a candidate) has not been elected to respective office, and Has not filed a final or dissolution report Before termination, the governing body of the political subdivision must consider the proposed termination in a regularly scheduled open meeting See Section , Election Code 71 Summary 1. Accept and date stamp filed documents 2. Do not alter them 3. Copy and make available required forms 4. Retain CTA for two years after termination and campaign finance reports for two years after filing. 5. Make campaign finance reports available to public, without redaction 6. Certain School Districts: Post trustee reports online 7. PFS: Deliver forms; maintain required records; send proper notices 8. Counties: Deliver required information in judicial campaigns to Commission 24
26 Chapter 255, Election Code POLITICAL ADVERTISING 73 What is Political Advertising? "Political advertising" is a defined term Election Code (16) Ethics Commission Rules 20.1(13) Promotes a particular outcome in an election Supporting or opposing a candidate or officeholder Advocating the passage or defeat of a measure Political Advertising Political advertising containing express advocacy must include disclosure statements Such as Political Advertising by Jane Doe Highway right-of-way notice Cannot misrepresent holding office Cannot misrepresent identity or true source See Political Advertising Guide on TEC website Contact Texas Department of Transportation about signs along highways Elec. Code ,.006,.004,.005,
27 Political Advertising An officer or employee of a political subdivision may not spend or authorize the spending of public funds for political advertising A person who violates this section commits a Class A misdemeanor The prohibition applies to any officer or employee of a political subdivision including school districts. If a school district employee or officer uses school district resources in violation of the prohibition, the employee could be fined by TEC or held criminally liable Elec. Code What Constitutes the Spending of Public Funds for Political Advertising? Includes both the use of FUNDS, RESOURCES, and FACILITIES Political Advertising Not allowed: Spending or authorizing the spending of public funds for political advertising Purchasing or authorizing the purchase of materials for use in creating political advertising Using existing resources to create, display, or distribute political advertising Use of paid time of municipal employees to create or distribute political advertising EAO 45 - Use of school mail system not okay EAO Allowing political advertising to be placed in non-public area not okay, even if all candidates or all sides of a measure are allowed to do it 78 26
28 Political Advertising What is allowed: Public resources for a communication that factually describes the purposes of a measure, such as: explanatory material about what is on the ballot purposes of the election election dates polling places If a political subdivision is unsure, contact TEC beforehand 79 Political Advertising: Two Extremes and the Area In-Between Vote for the Bonds - Not Okay Road Bond Election, May 15 - Okay Violations often occur because includes a motivational slogan or call to action such as: Good roads are the foundation of a good community Put people first Show that you care about your county 80 Political Advertising: Two Extremes and the Area In-Between Question to ask yourself, What are our goals? If trying to get right up to the line, you may likely draw a complaint and possible penalty Remember: No matter how much factual information about the purposes of a bond election is in a communication, any amount of advocacy is impermissible 81 27
29 Example City council member s refrigerator magnet Ethics Advisory Opinion No. 506 (2012) What is Political Advertising? Self-promotion of a public officer The Commission found that the magnet was political advertising Thus, public funds could not be used 84 28
30 Safe-Harbor No more than two pictures and pictures cover < 20% of page No more than eight I, Me the city council member As a whole it is: Informational rather than self-promotional Does not advocate passage or defeat of measure Does not support or oppose candidate for nomination or election 1 T.A.C (Newsletter of Public Officer of a Political Subdivision) 85 Example #2 A county prepared a one page brochure regarding a ballot measure to authorize the creation of a county assistance district and impose a sales and use tax to finance its operations. Ethics Advisory Opinion No. 531 (2015)
31 When the Prohibition Does Not Apply The use of public funds to distribute the brochure was permissible, so long as the brochure did not contain information the employee or officer knew was false 88 Summary Spending of public funds includes: Monetary funds Political subdivision s resources Political subdivision s facilities Summary The prohibition does not apply to a communication that factually describes the purposes of a measure election Any amount of advocacy is impermissible 30
32 Summary Communications describing a measure cannot contain information the officer or employee knows is false A violation could result in a fine imposed by the Commission or criminal liability. Check other applicable laws Municipal Regulation of Political Signs (Local Gov t Code ) Restricts the way municipalities may regulate certain political signs on private property Gift Laws: Can I Take It? 93 31
33 Public Servant Gift Restrictions Public servants are subject to many gift restrictions: Bribery Honoraria (for services b/c of official position) Lobbyist Gifts General Restrictions (Penal Code 36.08) Benefit from person under your authority Should Nots for State Officers & Employees Gov t Code Campaign Finance Corporate, Labor Org. Contributions Moratorium; Courthouse, Capitol Federal Restrictions 94 Restrictions Also Apply to Givers Gift restrictions also apply to person giving gift, such as: Penal Code Cannot give gift to public servant if you know the public servant is prohibited from accepting it Bribery Lobbyist Gifts Campaign Finance Federal Restrictions 95 Penalties Most ethics laws carry criminal or civil penalties for violations Violations may result in Termination of employment Monetary penalties Criminal penalties (incl. jail time) Other action 96 32
34 Can I Take It? Public servants are often offered gifts ( benefits ) Money Offer of employment To be permissible, must be okay under all laws, agency rules, and policies BUT an activity that is legal may raise appearance issues 97 Permissible Under Agency Laws & Policies Permissible Under Campaign Finance Law Permissible Under Lobby Law Permissible Under Penal Code 98 Goals Overview of Gift Restrictions Help Recognize Red Flags Tools for making ethical decisions Direction & Resources 99 33
35 Gift Laws Permissibility depends on many factors Who is it from? What is it? Why is it offered? 100 Questions to Ask The answers will help spot issues And determine: Is it okay under agency rules and policies? Is it okay under bribery law? Is it okay under honoraria law? Is it okay under lobby law? Is it okay under Penal Code gift laws (36.08)? Is it okay under the campaign finance law? Is it okay under federal law? 101 Bribery Cannot offer, give, solicit, or accept a benefit as consideration for an official act Exchange or quid pro quo Includes agreeing to perform an official act Vote, recommendation, other exercise of official discretion
36 Bribery A person commits an offense by offering, conferring, or agreeing to confer on another, or soliciting, accepting, or agreeing to accept a benefit as consideration for a decision, opinion, recommendation, vote, or other exercise of official discretion as a public servant or to violate a duty imposed by law on a public servant. Penal Code Benefit A benefit is anything reasonably regarded as pecuniary gain or pecuniary advantage. Penal Code 36.01(3) 104 Examples of Benefits $50 Clock $160 Rifle $60 Meal Tickets to football game Hunting trip Future employment
37 Not a Benefit Cup of coffee Trinkets of minimal value Coffee mug Keychain Gimme caps But can still appear inappropriate 106 Honorarium Public servant cannot accept an honorarium for services that were requested because of official status Honorarium includes Gift Payment Compensation Penal Code 36.07(a) 107 Honorarium Not prohibited: Meals Transportation Lodging IF provided for conference or similar event where you are providing services AND services are more than merely perfunctory
38 Penal Code Gift Laws (36.08) Public servants (PS) cannot accept a benefit from certain persons, depending on who the person is Examples: PS in regulatory agency: anyone subject to regulation by PS or agency PS exercising discretion in connection w/contracts: anyone interested in contract Legislature, Gov., Lt. Gov., employees: anyone at all 109 Penal Code Gift Laws (36.08) Boiled down Public servant cannot accept a benefit from a person who is subject to that person s jurisdiction (authority) 110 Exceptions Certain benefits are not prohibited by this law Item worth less than $50 Other than cash, check, negotiable instrument Benefit given based on independent relationship Kinship (family) Personal relationship Professional relationship Business relationship
39 Exceptions Fee for lawfully entitled services E.g., providing work outside your official capacity Payment must reflect value of work Political contributions Item issued by governmental entity allowing use of its property or facilities Food, Entertainment, Transportation, Lodging When accepted as a guest and Any reporting requirements are met 112 Unsolicited Benefits If you receive an unsolicited benefit that you cannot accept May donate to recognized tax-exempt charity 113 Even If OK Under One Law It must be OK under all laws Always make sure your agency s laws, rules, and policies permit the acceptance of a benefit Always consider whether accepting a benefit raises the appearance of impropriety
40 When Offered a Gift Where do you start? Begin with three questions: Who is it from? What is it? Why is it offered? 115 Resource: Can I Take It? Guide 116 Resource: Flow Chart Intended as illustration only Not always a definitive answer Cannot account for all laws, policies, or facts Help recognize red flags & trends Prompt further questions What more do I need to know? Not legal advice Seek personal counsel for that
41 Example 1 You are a city council member. A potential contractor for the city offers to take you to lunch no strings attached! You ve never met him before. Is the lunch acceptable?
42 Example 2 You are a county employee. The county is currently being sued by a local business and the business owner is a personal friend of yours. The business owner offers you two tickets to the Spurs game tomorrow. Are the tickets acceptable? 121 Example 3 Judy is a school district employee. She gives a presentation to a local trade association regarding recent decisions made by the school board. After the presentation, the association gives Judy season passes to Fiesta Texas in appreciation. Can she keep them? 122 Red Flags A gift or benefit: Someone expecting something in return Someone subject to your jurisdiction Someone you don t know outside your official position Someone who is not present Given because of official status Lobbyist (if you are state officer/employee) High value Travel or lodging
43 Key Questions Questions to ask: Who is giving it? What is it? Why are they giving it? 124 OTHER FORMS 125 Conflict of Interest Forms Chapter 176, Local Gov t Code Certain local gov t officials must file Form CIS relating to a person that the gov t entity has contracted with or is considering contracting with if the officer/member or family member has a certain business relationship or gift history with that person exceeding certain threshold amounts A person who contracts or seeks to contract with the local gov t entity must file Form CIQ disclosing their affiliation and business relationship with each member of the governing body and executive officer of the entity 42
44 Conflict of Interest Forms Chapter 176, Local Gov t Code Filed w/ records administrator and, in certain instances, posted on the Internet See Att y Gen. Op. No. GA-0446 (2006) at TEC developed forms, but forms are not filed with TEC Law amended eff. Sep. 1, 2015 (HB 23) Forms Updated November 30, 2015 TEC cannot enforce or interpret these requirements Disclosure of Interested Parties Form 1295 Form 1295 required for contracts between governmental entities and business entities that requires vote of governing body of governmental entity; or has a value of at least $1 million. Disclosure of Interested Parties Form 1295 Business entity creates form on TEC filing app then prints the form and delivers it to governmental entity Governmental entity acknowledges form using filing app. Requirements amended during last legislative session Section , Gov t Code 43
45 Disclosure of Interested Parties Form 1295 For Contracts entered into after Jan.1, 2008: Unsworn declaration replaces notary; and Form 1295 no longer required for: (1) a sponsored research contract of an institution of higher education; (2) an interagency contract of a state agency or an institution of higher education; (3) a contract related to health and human services if: (A) the value of the contract cannot be determined at the time the contract is executed; and (B) any qualified vendor is eligible for the contract; Disclosure of Interested Parties Form 1295 (4) a contract with a publicly traded business entity, including a wholly owned subsidiary of the business entity; (5) a contract with an electric utility, as that term is defined by Section , Utilities Code; or (6) a contract with a gas utility, as that term is defined by Section , Utilities Code. Resources Questions? Read TEC instructions and guides Filing schedules and guides online at: Legal or Technical: TEC (512)
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