Control Number : 44547
Item Number: 868
Addendum StartPage : 0
SOAH DOCKET 473-15-3595
PUC DOCKET 44547
^^ Pi i ^
APPLICATION OF CENTERPOINT
§
BEFORE THE
ENERGY HOUSTON ELECTRIC, LLC §
i-rLl;;;; CLE;^,;;
TO AMEND A CERTIFICATE OF
§
CONVENIENCE AND NECESSITY FOR §
PUBLIC UTILITY COMMISSION
A PROPOSED 138-KV TRANSMISSION §
LINE WITHIN GRIMES, HARRIS, AND §
OF TEXAS
WALLER COUNTIES
§
THE TUCKER AND WALTER PROPERTIES' RESPONSES TO
CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC'S
FIRST REQUEST FOR INFORMATION
The Tucker and Walter Properties file these responses to CenterPoint Energy Houston
Electric, LLC's ( "CenterPoint Energy") First Request for Information 1-1 to 1-3 to Tucker and
Walter Properties. Tucker and Walter Properties agree and stipulate that all parties may treat
these responses as if the answers were filed under oath.
Respectfully submitted,
Catherine J. Webking
State Bar No. 31050055
(512) 542-7036
(512) 542-7236 (Fax)
cwebkingagardere com
Andres Medrano
State Bar No. 24005451
(512) 542-7013
(512) 542-7213 (Fax)
amedrano n gardere. com
GARDERE WYNNE SEWELL LLP
600 Congress Avenue
Suite 3000
Austin, Texas 78701-2978
ATTORNEYS FOR THE TUCKER AND
WALTER PROPERTIES
1
^
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument will be served via
facsimile or first-class mail in accordance with SOAH Order No. 4, on this 24th day of July,
2015.
Barbara
t
SOAH DOCKET 473-15-3595
PUC DOCKET 44547
APPLICATION OF CENTERPOINT
ENERGY HOUSTON ELECTRIC, LLC
TO AMEND A CERTIFICATE OF
CONVENIENCE AND NECESSITY FOR
A PROPOSED 138-KV TRANSMISSION
LINE WITHIN GRIMES, HARRIS, AND
WALLER COUNTIES
§
§
§
§
§
§
§
BEFORE THE
PUBLIC UTILITY COMMISSION
OF TEXAS
THE TUCKER AND WALTER PROPERTIES' RESPONSES TO
CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC'S
FIRST REQUEST FOR INFORMATION
1-1 THROUGH 1-3
No. 1-1:
Identify and provide any documents that your witnesses will introduce,
sponsor, or rely upon.
RESPONSE 1-1:
The witnesses for the Tucker and Walter Properties, Blake Hamilton and Brian Almon, will
introduce and sponsor their pre-filed Direct and Cross-Rebuttal testimonies. The witnesses may
also introduce other exhibits relevant to their testimonies that have been filed or introduced as
exhibits by other parties such as Responses to Requests for Information, attachments to
testimonies, or any materials from the Application and its attachments and related documents. A
complete exhibit list is not available at this time and is premature as discovery in this case is
ongoing and testimony by Commission Staff, Cross-Rebuttal testimony by intervenors, and
Rebuttal testimony by CenterPoint Energy has yet to be filed and reviewed.
The witnesses for the Tucker and Walter Properties will rely upon all documents identified in
their testimonies, documents that are reviewed as part of the regular course of their profession
and practice, and all documents filed in this case or introduced as exhibits by any party.
3
Sponsor and Witness: Blake Hamilton and Brian Almon
SOAH DOCKET 473-15-3595
PUC DOCKET 44547
APPLICATION OF CENTERPOINT
ENERGY HOUSTON ELECTRIC, LLC
TO AMEND A CERTIFICATE OF
CONVENIENCE AND NECESSITY FOR
A PROPOSED 138-KV TRANSMISSION
LINE WITHIN GRIMES, HARRIS, AND
WALLER COUNTIES
§
§
§
§
§
§
§
BEFORE THE
PUBLIC UTILITY COMMISSION
OF TEXAS
THE TUCKER AND WALTER PROPERTIES' RESPONSES TO
CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC'S
FIRST REQUEST FOR INFORMATION
1-1 THROUGH 1-3
No. 1-2:
For each of the Tucker and Walter Properties' testifying experts provide:
a. the expert's name, address, and telephone number;
b. the subject matter(s) on which the expert will testify;
c. the facts known by the expert that relate to or form the basis of the
expert's mental impressions and opinions formed or made in
connection with this case;
d. the expert's mental impressions and opinions formed or made in
connection with the case, and any methods used to derive them;
e. any bias of the witness;
f. all documents, tangible things, reports, models, or data compilations
provided to, reviewed by, or prepared by or for the expert in
anticipation of the expert's testimony; and
g. the expert's current resume and bibliography.
RESPONSE 1-2:
Please see the Direct Testimonies of Blake Hamilton and Brian Almon in which all of the listed
items are identified. See response to RFI 1-1 for a description of the documents reviewed by the
experts in preparation for testimony; each of these documents is publicly filed or already in the
possession and control of CenterPoint Energy.
4
Sponsor and Witness: Blake Hamilton and Brian Almon
SOAH DOCKET 473-15-3595
PUC DOCKET 44547
APPLICATION OF CENTERPOINT
ENERGY HOUSTON ELECTRIC, LLC
TO AMEND A CERTIFICATE OF
§
§
§
BEFORE THE
CONVENIENCE AND NECESSITY FOR
§
PUBLIC UTILITY COMMISSION
A PROPOSED 138-KV TRANSMISSION
LINE WITHIN GRIMES, HARRIS, AND
WALLER COUNTIES
§
§
§
OF TEXAS
THE TUCKER AND WALTER PROPERTIES' RESPONSES TO
CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC'S
FIRST REQUEST FOR INFORMATION
1-1 THROUGH STAFF 1-3
No. 1-3:
Identify each consulting expert whose mental impressions or opinions
have been reviewed by an expert you expect to call to testify at the hearing
on the merits. For any consulting expert provide:
a. the expert's name, address, and telephone number;
b. the facts known by the expert that relate to or establish the expert's
mental impressions and opinions formed or made in connection with
this case;
c. the expert's mental impressions and opinions formed or made in
connection with the case, and any methods used to derive them;
d. any bias of the witness;
e. all documents, tangible things, reports, models, or data compilations
provided to, reviewed by, or prepared by or for the expert in
f.
anticipation of the expert's testimony; and
the expert's current resume and bibliography.
RESPONSE 1-3:
The Tucker and Walter properties have no cobsul"ting expert whose mental impressions or
opinions have been reviewed by either Mr. Hamilton or Mr. Almon.
Gardere0l- 6915408v.1
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Sponsor and Witness: Blake Hamilton and Brian Almon