
Texas likes to tell itself a flattering story. It is the myth of rugged self-government: a Republican legislature, a Republican governor, and the ironclad presumption that these together guarantee conservative governance. Yet, as the State Leadership Initiative’s Shadow Government report makes clear, this ideal is increasingly a mirage. Behind the scenes, unelected national associations have embedded themselves so deeply into Texas’s administrative bloodstream that the ballot box no longer delivers the policy outcomes voters expect. The result is not a drift, but a displacement: conservative electoral victories followed by progressive administrative realities.
Consider the structural mechanics. Texas agencies belong to national bodies whose influence is not advisory, but directive. They produce “best practices,” model policies, and grant templates that are adopted wholesale by career officials, often without the knowledge, let alone the approval, of elected leadership. These organizations, from the National Association of State Procurement Officials (NASPO) to the Association of State Highway and Transportation Officials (AASHTO), market themselves as politically neutral. In practice, they act as conduits for the very DEI, ESG, and identity-based governance that Texas voters have repeatedly rejected.
Transportation is a case study. AASHTO’s 2020 Equity Resolution redefined transportation policy in explicitly racial terms, instructing state DOTs to direct contracts and investments based on identity categories rather than engineering need or cost-efficiency. Texas, despite legislative hostility to such criteria, remains tied to these frameworks through its membership. Disadvantaged Business Enterprise quotas, once a federal imposition, have been normalized as an industry standard by AASHTO, embedding them in procurement long after Congress or Austin has weighed in.
Procurement policy offers another example. NASPO has institutionalized supplier diversity mandates that prioritize contracts for minority- and women-owned businesses, embedding demographic preferences into bid scoring systems. Texas agencies, guided by NASPO training and certification protocols, have adopted these preferences under the guise of modernization. The effect is to shift procurement away from value-for-money competition toward ideological conformity.
The energy and environmental sectors show the same pattern. The National Association of Regulatory Utility Commissioners (NARUC) has embraced the Biden administration’s Justice40 initiative, which directs that 40% of federal climate spending benefit “overburdened” communities. That sounds benign until one reads the fine print: racial and environmental criteria replace traditional measures like reliability and ratepayer fairness. Texas utility regulators, through NARUC training and policy toolkits, are pressed to redesign rate structures and investment plans to achieve these federally defined equity outcomes, regardless of whether the Texas Legislature has mandated them.
Meanwhile, the National Association of State Energy Officials (NASEO) has used federal grant implementation to push “equity-based energy planning” and electrification mandates. Texas, with its abundant fossil fuel resources and energy independence ethos, finds itself nudged toward net-zero building codes and climate-justice metrics not by statute, but by bureaucratic compliance with national association norms.
Public health and social policy are no exception. The Association of State and Territorial Health Officials (ASTHO) has declared “structural racism” a public health emergency, embedding this diagnosis into all technical assistance and member programming. It has coordinated with federal agencies to suppress dissenting views on COVID policy, abortion, and gender ideology. In Texas, local health departments take their cues from ASTHO frameworks, ensuring that ideological commitments survive changes in gubernatorial policy.
Education may be the most sensitive domain. The Council of Chief State School Officers (CCSSO) and the National Association of State Boards of Education (NASBE) promote “anti-racist” pedagogy, gender identity accommodations, and equity-of-outcome benchmarks. Texas superintendents and school board members attend trainings, adopt curricular frameworks, and pursue accreditation under these national bodies. The result is that legislative bans on certain content or mandates for parental oversight are quietly diluted in practice by bureaucratic adherence to national association standards.
The financial sphere tells a similar story. The National Association of State Treasurers (NAST) and the National Association of State Auditors, Comptrollers and Treasurers (NASACT) have embedded ESG investing and DEI mandates into public finance management. Texas treasury and audit officials, through their participation, are pressured to align with investment strategies that prioritize climate risk and board diversity over return on investment, even when the legislature or governor has signaled or even legislated opposition.
This is not accidental policy creep. It is a structural inversion of democratic accountability. Texans elect lawmakers to enact laws, yet the operational rules of governance are increasingly set by distant organizations with no electoral mandate. These groups operate behind a veneer of professional consensus, but their consensus is an ideological filter. They make no allowance for the cultural, economic, or political particularities of Texas; their policy prescriptions are designed for all states, red and blue alike.
The result is administrative convergence. A Republican-led Texas Department of Transportation applies the same race-conscious contracting rules as a Democratic-led California agency. Texas school boards trained by NASBE adopt the same gender-identity policies as those in New York. Texas Medicaid administrators briefed by the National Association of Medicaid Directors absorb the same equity mandates as their counterparts in Illinois.
What this means in practice is that elections no longer guarantee policy change. The governor and legislature may issue orders against DEI trainings, but association-led technical assistance keeps them alive under other labels. A legislature may prohibit ESG considerations in investment, yet national rankings, model fiduciary guidelines, and professional certifications still make ESG the de facto standard.
This is not federal overreach in the traditional sense; it is something more insidious. It is governance outsourced to a cartel of national associations whose incentives align with the permanent bureaucracy and with federal agencies, not with the citizens of Texas. It is a shadow government in every meaningful sense: visible in name, invisible in accountability, and resistant to electoral correction.
The Shadow Government report is right to warn that this system thrives in darkness. The solution is not resignation, but structural disentanglement. Texas can withdraw from associations whose agendas conflict with state law, as it already did when it removed itself from the National Association of Attorneys General in response to its leftward shift. It can prohibit the adoption of external model policies without legislative approval. It can build parallel associations, as the State Financial Officers Foundation has done in finance, to create policy infrastructure that reflects its own priorities. Above all, it can require transparency: every agency’s association memberships, policy adoptions, and training curricula should be public record.
Texas has the legal authority to reclaim control of its governance. What it has lacked is clarity about the scale and nature of the problem. The Shadow Government report provides that clarity. It shows that the danger is not that Texas will lose a legislative fight to progressives in Austin, but that it has already ceded much of its governing machinery to progressives in Washington, New York, and the boardrooms of national associations.
If Texans want their votes to mean something, they must insist that their elected officials govern not only in the Capitol, but in the operational codes, procurement standards, training curricula, and regulatory frameworks that actually determine what government does. Otherwise, the myth of Texas self-government will remain exactly that: a myth.

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