According to the Legislative Budget Board (LBB), SB 2148 is projected to result in a negative net impact of $659,906 to General Revenue over the biennium ending August 31, 2027. The fiscal impact stems primarily from the operational requirements placed on the Public Utility Commission of Texas (PUC) to implement and coordinate the newly mandated emergency preparedness and security simulation exercises with ERCOT and electric utility providers.

To meet the bill’s requirements, the PUC estimates it will need to hire three additional full-time employees (FTEs)—specifically, Project Specialist V positions—to support its Critical Infrastructure Security and Risk Management team. These personnel will manage logistics for the exercises, conduct training and outreach with utility companies, and ensure regular participation in tabletop simulations focused on physical attacks or threats to critical facilities. Each position would incur approximately $105,304 in annual salary and benefits, with additional operational costs, including travel, payroll contributions, and IT needs, bringing the yearly total to roughly $329,953.

The bill does not provide an appropriation but would serve as the legal basis for funding such appropriations in future budgets. The PUC also anticipates information technology costs of approximately $8,100 per year, but no significant fiscal implications are expected for local governments.

SB 2148 represents a measured and proactive response to growing concerns over the vulnerability of Texas’s electric grid to physical attacks. It directly addresses gaps in preparedness among electricity providers by establishing a statutory framework for regular, state-coordinated emergency response exercises. Currently, there are no laws requiring utilities to conduct physical security drills or to coordinate with law enforcement and state agencies on such matters. SB 2148 fills that void by mandating biennial simulated or tabletop exercises to test the grid's resilience and ensure all relevant entities—from ERCOT to local law enforcement—understand their roles during a security threat.

Texas Policy Research recommends that lawmakers vote YES on SB 2148 based on its alignment with multiple liberty principles. It promotes personal responsibility among electricity providers by requiring them to participate proactively in preparedness exercises and coordinate with law enforcement. It supports individual liberty and private property rights by explicitly protecting sensitive infrastructure location data from disclosure. Importantly, it upholds the value of limited government by avoiding the creation of new agencies or expansive rulemaking authority, focusing instead on collaboration and existing agency roles.

From a fiscal standpoint, while the bill carries a modest cost to the state—approximately $330,000 per year to support three new staff positions at the Public Utility Commission—it is a reasonable investment in infrastructure security, given the potential statewide consequences of a coordinated attack or catastrophic failure.

The intent, structure, and safeguards of SB 2148 indicate a responsible approach to securing critical grid infrastructure without overreaching into the private sector or encroaching on civil liberties.

• Individual Liberty: The bill respects individual liberty by enhancing public safety without encroaching on civil or constitutional rights. The bill addresses a critical vulnerability—physical attacks on electric infrastructure—through non-intrusive means such as simulated and tabletop exercises. Notably, it protects sensitive information by explicitly stating that utilities are not required to disclose the specific locations of critical substations to the government or ERCOT for the purposes of these exercises​. This protects both individual and corporate privacy, a key concern for liberty-focused stakeholders.
• Personal Responsibility: The bill imposes clear expectations on electric providers to take responsibility for preparing for emergencies that could endanger millions of Texans. It promotes a culture of responsibility among both public and private actors by requiring coordination with law enforcement and state entities in advance of a crisis. This proactive approach shifts the paradigm from reactive to preventative—reinforcing that critical infrastructure owners have a duty to safeguard public interests through meaningful preparation.
• Free Enterprise: Although the bill mandates participation in emergency preparedness drills, it does not interfere with market dynamics or impose regulatory burdens that would distort competition or innovation. By reinforcing grid stability and disaster preparedness, the bill actually helps protect the economic environment necessary for free enterprise to flourish. A secure and reliable power grid is fundamental to the operation of virtually every industry in Texas, and this legislation works to preserve that foundation.
• Private Property Rights: The bill respects private property rights by allowing utilities to retain control over the disclosure of sensitive infrastructure details, particularly the locations of critical substations. While it does involve utilities in mandatory exercises, it does not authorize government access to physical property or mandate disclosure of proprietary systems. The attestation requirement (confirming coordination with law enforcement) upholds accountability while avoiding undue intrusion.
• Limited Government: The bill promotes limited government by leveraging existing agencies and infrastructure, such as the Public Utility Commission and ERCOT, without expanding their regulatory authority or creating new bureaucracies. The bill does not include rulemaking provisions, nor does it impose punitive mechanisms or permit ongoing surveillance or control of private entities. It strikes a balance between state-level coordination and local execution by private sector actors, embodying a limited, purposeful use of government to ensure public safety.

• HB 4851 (Same As)