CCN Territory Disputes in Collin County: What to Check Before Land Crosses a Water Provider Boundary

What does a CCN give a water or sewer provider?

It gives one retail utility the exclusive right to serve a mapped area, and the duty to serve it. The Public Utility Commission of Texas issues certificates of convenience and necessity under Texas Water Code Chapter 13, Subchapter G. Section 13.242 bars investor-owned utilities and water supply corporations from selling retail water or sewer service without one.

Section 13.250 says a CCN holder "shall serve every consumer within its certified area" and render continuous and adequate service. That is the part developers lean on. It is also where the arguments start, because the statute does not say the plant, the lines or the storage already exist.

Why do Collin County growth corridors have so many boundary problems?

Many CCNs here were drawn for rural demand, long before today's growth. Around McKinney, Prosper, Celina, Anna and Melissa, those old service areas now overlap newer city limits, extraterritorial jurisdictions and district boundaries.

One tract can straddle two holders, sit on a line nobody has checked against a survey, or fall inside a CCN whose system was sized for farmhouses.

City limits and CCNs are separate. When a city annexes land, Section 13.255 lets the city and the holder agree in writing who serves it. If they have not agreed within 180 days of the city's written notice, the city can apply to the PUC for single certification.

How do you confirm which CCN covers your tract?

Start with the PUC's own map, then check it against your boundary survey. The PUC's CCN mapping resources include a Water and Sewer CCN Viewer that searches by address or CCN number. Its boundaries come from the PUC's official CCN data, which is also downloadable as shapefiles for GIS and CAD.

Use the survey, not a general area map or a plat. Check water and sewer separately. They are different certificates and often different holders.

If nothing shows, a city or district may serve the area without a CCN. The PUC's mapping staff take written requests to identify the provider.

Does a CCN mean the provider has capacity for your project?

No. Holding the rights and having the capacity are two different facts. A provider can hold the CCN and still lack the treatment, transmission, storage or collection capacity for your project. When capacity is short, improvements come before service, and their cost and schedule often land on the developer.

That is why utility due diligence goes past naming the holder. Send the holder a written request with your demands, phasing and fire flow. Ask what it must build to serve you, who pays, and when it can sign.

What can you do if the CCN holder cannot or will not serve?

Texas law has three PUC routes out of a CCN, and none of them is fast for a project already under contract.

• Expedited release, Section 13.254(a-1). For a tract of at least 50 acres not in a platted subdivision receiving service. You first send a written service request covering area, timing, flow, pressure and fire protection, and give the holder at least 90 days. You then show it refused, cannot serve on comparable terms, or tied service to costs not properly allocable to you, and that another provider can serve.
• Streamlined expedited release, Section 13.2541. For a tract of at least 25 acres not receiving water or sewer service, in a qualifying county. One qualifying group is counties next to a county of at least 1.2 million people, and Collin County borders Dallas County. The PUC must grant the petition within 60 days of filing.
• Decertification, Section 13.254(a). After notice and hearing, the PUC can revoke or amend a certificate if the holder has never provided, is no longer providing, is incapable of providing, or has failed to provide continuous and adequate service. The PUC or the holder starts this one, not the landowner.

Release is not free. The holder can be owed compensation set by independent appraisers, and no other utility may serve the released area until it is paid. Release is also closed to land in a platted subdivision already receiving service, and to land in a city of more than 500,000, or its extraterritorial jurisdiction, where the city's utility holds the CCN.

Where does cost participation show up?

Usually in the service agreement, when the holder can serve only after improvements you fund. Think line extensions, lift stations, storage or a plant expansion. Reimbursement as later projects connect may be partial or uncertain, so estimate that exposure before closing.

Can a MUD or a private plant get around a CCN?

Sometimes, but never by ignoring the holder. The PUC's mapping guidance says districts and cities do not need a CCN unless they want to serve inside an existing one. Under Section 13.252, the PUC can stop any retail utility that extends service into another holder's certificated area. A MUD inside an existing CCN still needs a release, a decertification or an agreement.

Private facilities have the same limit. Section 13.242(b) says a person that is not a retail public utility may not build facilities serving more than one connection off its own property inside another holder's certificated area without that holder's written consent.

Where only a water CCN covers the tract, a private wastewater plant under a TCEQ permit can be an option. If a private utility will own it and sell retail sewer service, that utility needs its own sewer CCN.

What should you confirm before closing on a Collin County tract?

Answer each item yes or no. If any answer is no or unknown, your schedule has a risk you have not priced.

1. Do you know the water CCN holder and the sewer CCN holder for the entire parcel, from the PUC's data laid over your survey?
2. Have you checked the PUC's filings for any pending amendment, release or dispute that touches the parcel?
3. Has the holder answered a written service request with your demands, phasing and fire flow?
4. Do you know which improvements the holder requires and who pays for them?
5. Do you know how long the holder's own approval takes for a project your size?
6. If the city will annex the tract, do you know whether the city or the CCN holder will serve it?

Take the answers to your engineer and utility attorney, and ask which path keeps the closing date.

Limits: this is general education on Texas Water Code Chapter 13 as it reads in October 2026, not legal advice. Release and decertification petitions are legal filings, and the PUC's rules in 16 TAC Chapter 24 set the details.

Frequently asked questions

How do we confirm the exact CCN boundary for a Collin County tract?

Use the PUC's CCN Viewer or its CCN shapefiles, laid over your boundary survey. A title report or a city map alone does not reliably show it.

If our tract crosses two CCN holders, do we need agreements with both?

Possibly, depending on how the tract is planned and platted. Resolve it early with both providers and your attorney.

Is a decertification petition a fast way to deal with an unresponsive holder?

Not usually. The streamlined release has a 60-day grant deadline, but the appraisal and compensation steps after it can run for months. Regular decertification is a PUC proceeding with notice and a hearing. Treat both as a parallel track, not a replacement for negotiating service.

What is the biggest CCN mistake developers make in Collin County?

Assuming the nearby city will serve the site. CCN rights are separate from city limits, and a site inside a city can still sit in another holder's exclusive service area.

I'm a developer under contract on a 40-acre tract near Celina, and the water supply corporation says it needs a new line before it can serve us. What should I ask before my feasibility period ends?

Ask in writing what it must build, who pays, whether any cost comes back as others connect, and when it can sign. At 40 acres with no current service, a streamlined release may be open to you, with compensation. Price both paths.

I'm a civil engineer in Texas laying out a subdivision where the sewer CCN holder has no plant nearby. Can my client build a private plant instead?

Not inside that holder's certificated sewer area without its written consent, under Section 13.242(b). The options are consent, a release, or an agreement for the holder to own or operate the plant. The plant needs a TCEQ permit in every case.

Related resources

• CCN Disputes in West Houston: What Happens When Your Development Lands Inside Someone Else's Certified Service Area
• McKinney Utility Availability Study: What Developers Need Before Submitting a Plat in Collin County's Fastest Growing City
• NTMWD Connection vs. Private Treatment: The McKinney Developer's Guide to Choosing the Right Wastewater Path
• Impact Fees and CIP Timing: Why Phasing Costs Blindside Developers When the Capital Improvement Plan Schedule Does Not Match Their Build Out

Buying Collin County land near a CCN boundary?

We check who serves the tract, what the provider can deliver, and what the design has to carry before you commit to the land.

We specialize in:

• Site feasibility and utility due diligence
• Utility service requests and capacity coordination with providers
• Water distribution and storage design
• Wastewater collection and lift station design
• Private wastewater treatment design and TCEQ permitting
• Site civil design for land development

Modern Engineering Solutions, McKinney, Texas. Contact: (214) 833-6748 or mod-eng.com