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Control Number : 44547
Item Number : 43
Addendum StartPage : 0
SOAH DOCKET NO. 473-15-3595
L PUC DOCKET NO. 44547
APPLICATION OF CENTERPOINT
ENERGY HOUSTON ELECTRIC, LLC
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STAT-F OFFICE
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TO AMEND A CERTIFICATE OF
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CONVENIENCE AND NECESSITY FOR §
A PROPOSED 345-KV TRANSMISSION §
LINE WITHIN GRIMES, HARRIS, AND §
WALLER COUNTIES
§
OF
ADMINISTRATIVE HEARINGS
SOAH DOCKET NO. 473-15-3596
PUC DOCKET NO. 44649
APPLICATION OF CROSS TEXAS
TRANSMISSION, LLC TO AMEND ITS
CERTIFICATE OF CONVENIENCE
AND NECESSITY FOR THE
LIMESTONE TO GIBBONS CREEK
345-KV TRANSMISSION LINE IN
BRAZOS, FREESTONE, GRIMES,
LEON, LIMESTONE, MADISON, AND
ROBERTSON COUNTIES
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§
§
§
§
§
§
§
§
STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
COMMISSION STAFF'S MOTION TO CONSOLIDATE
Commission Staff (Staff) of the Public Utility Commission of Texas (Commission) files
this Motion to Consolidate.
Staff requests that the State Office of Administrative Hearings
consolidate the transmission line proceeding involving CenterPoint Energy Houston Electric,
LLC (CenterPoint Energy)' with the transmission line proceeding involving Cross Texas
Transmission, LLC (Cross Texas).2 In support of its Motion to Consolidate, Staff states the
following:
I See generally Application of CenterPoint Energy Houston Electric, LLC to Amend a Certificate of
Convenience and Necessityfor a Proposed 345-Kv Transmission Line within Grimes, Harris, and Waller Counties,
SOAH Docket No. 473-15-3595, PUC Docket No. 44547 (Apr. 24, 2015).
2
See generally Application of Cross Texas Transmission, LLC to Amend its Certificate of Convenience
and Necessity for the Limestone to Gibbons Creek 345-kV Transmission Line in Brazos, Freestone, Grimes, Leon,
Limestone, Madison and Robertson Counties, SOAH Docket No. 473-15-3596, PUC Docket No. 44649 (Apr. 24,
2015).
SOAH Docket Nos. 473-15-3595/3596
PUC Docket No. 44547/44649
Staff's Motion to Consolidate
Page 1 of 6
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I. Summary of the Motion to Consolidate
The Public Utility Regulatory Act, Tex. Util. Code. §§ 11.001-66.016, requires that
separate transmission line proceedings must be consolidated when the proposed transmission
lines share a common point of interconnection.3 The Gibbons Creek Substation is the common
point of interconnection for the transmission lines proposed by CenterPoint Energy and Cross
Texas. Thus, these transmission proceedings must be consolidated.
II. Background
The transmission line proceedings initiated by CenterPoint Energy and Cross Texas arise
from what is commonly known as the Houston Import Project. The Houston Import Project
proposes the construction of a transmission line that:
(1) connects CenterPoint Energy's
Limestone Substation in Limestone County with the Texas Municipal Power Agency's Gibbons
Creek Substation in Grimes County and (2) connects Texas Municipal Power Agency's Gibbons
Creek Substation with CenterPoint Energy's Zenith Substation in Harris County. Attachment A
provides an approximate visual representation of the Houston Import Project.
In its application, CenterPoint Energy described its portion of the Houston Import Project
transmission line as "construct[ing] a new 345kV double-circuit transmission line ... extending
from the existing 345 kV Zenith Substation to the existing 345 kV Gibbons Creek Substation."4
Cross Texas described its portion of the Houston Import Project transmission line as
"constructing a new double-circuit 345 kV transmission line from the existing Limestone
Substation owned by CenterPoint Energy Houston Electric, LLC ... to the existing Gibbons
Creek substation owned by Texas Municipal Power Agency ...."5
III. Staff's Request to Consolidate
A.
Consolidation
The Gibbons Creek Substation in Grimes County is the common point of interconnection
for the transmission lines proposed by CenterPoint Energy and Cross Texas. Because there is a
3 See Tex. Util. Code § 37.0541.
4 CenterPoint Energy Application at 6.
5 CrossTexas Application at 4.
SOAH Docket Nos. 473-15-3595/3596
PUC Docket No. 44547/44649
Staff's Motion to Consolidate
Page 2 of 6
common point of interconnection between CenterPoint Energy's proposed transmission line and
Cross Texas' proposed transmission line, the Public Utility Regulatory Act requires that their
transmission line proceedings be consolidated.
The relevant provision of the Public Utility
Regulatory Act states:
The commission shall consolidate the proceeding on an application to obtain or
amend a certificate of convenience and necessity for the construction of a
transmission line with the proceeding on another application to obtain or amend a
certificate of convenience and necessity for the construction of a transmission line
if it is apparent from the applications or a motion to intervene in either proceeding
that the transmission lines that are the subject of the separate proceedings share a
common point of interconnection.6
Thus, Staff requests that the State Office of Administrative Hearings consolidate these
proceedings.
B.
Pre-hearing Conference and Notice of Consolidation
Staff requests that, in order to conserve judicial resources, the State Office of
Administrative Hearings schedule a joint pre-hearing conference for these proceedings.
Additionally, Staff also requests that, upon consolidation, both CenterPoint Energy and Cross
Texas be required to send notice to parties entitled to receive notice that these proceedings have
been consolidated.
IV. Conclusion
Staff requests that the State Office of Administrative Hearings consolidate these
proceedings.
Additionally, Staff requests that the State Office of Administrative Hearings
schedule a joint pre-hearing conference for these two transmission line proceedings.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
6
Tex. Util. Code § 37.0541.
SOAH Docket Nos. 473-15-3595/3596
PUC Docket No. 44547/44649
Staff's Motion to Consolidate
Page 3 of 6
Date: May 4, 2015
Respectfully Submitted,
Margaret Uhlig Pemberton
Division Director
Legal Division
Karen S. Hubbard
Managing Attorney
Legal Division
Sam Chang
State Bar No. 24078333
Attorney, Legal Division
Jacob J. Lawler
State Bar No. 24076502
Attorney, Legal Division
Thomas L. Tynes
State Bar No. 24085629
Attorney, Legal Division
Ralph J. Daigneault
State Bar No. 24040755
Attorney, Legal Division
A. J. Smullen
State Bar No. 24083881
Attorney, Legal Division
Public Utility Commission of Texas
1701 N. Congress Avenue
P.O. Box 13326
Austin, Texas 78711-3326
(512) 936-7261
(512) 936-7268 (facsimile)
sam.cha,ng@puc.texas.gov
jacob.lawler@puc.texas.gov
thomas.tynes@puc.texas.gov
ralph.daigneault@puc.texas.gov
aj.smullen@puc.texas.gov
Commission Staff of the Public Utility
Commission of Texas
SOAH Docket Nos. 473-15-3595/3596
PUC Docket No. 44547/44649
Staff's Motion to Consolidate
Page 4 of 6
SOAH DOCKET NO. 473-14-4953
PUC DOCKET NO. 44547
CERTIFICATE OF SERVICE
I certify that a copy of this document was served on all parties of record on May 4, 2015,
in accordance with 16 Tex. Admin. Code § 22.74.
Sam Chang
SOAH Docket Nos. 473-15-3595/3596
PUC Docket No. 44547/44649
Staff's Motion to Consolidate
Page 5 of 6
ATTACHMENT A
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SOAH Docket Nos. 473-15-3595/3596
PUC Docket No. 44547/44649
Staff's Motion to Consolidate
Page 6 of 6