R2008-046 2008-03-24RESOLUTION NO. R2008-46
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
PEARLAND, TEXAS, SUSPENDING THE APRIL 10, 2008, EFFECTIVE
DATE OF CENTERPOINT ENERGY RESOURCES CORP., D/B/A
CENTERPOINT ENERGY ENTEX AND CENTERPOINT ENERGY
TEXAS GAS (CENTERPOINT) REQUESTED RATE CHANGE TO
PERMIT THE CITY TIME TO STUDY THE REQUEST AND TO
ESTABLISH REASONABLE RATES.
WHEREAS, on or about March 6, 2008, CenterPoint Energy Resources Corp.,
d/b/a CenterPoint Energy Entex and CenterPoint Energy Texas Gas ("CenterPoint" or
"Company"), pursuant to Gas Utility Regulatory Act § 104.102 filed with the City of
Pearland a Statement of Intent to change gas rates in all municipalities exercising
original jurisdiction within its Texas Coast Division service area effective April 10, 2008;
and
WHEREAS, the Gas Utility Regulatory Act § 104.107 grants local regulatory
authorities the right to suspend the effective date of proposed rate changes for ninety
(90) days; and
WHEREAS, on or about March 6, 2008 simultaneous with the filing with the City,
CenterPoint filed a Statement of Intent to change gas rates for the Texas Coast
environs with the Railroad Commission of Texas referred to as Gas Utility Docket
("GUD") No. 9791.
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PEARLAND,
TEXAS:
Section 1. That the April 10, 2008, effective date of the rate request submitted
by CenterPoint on or about Mach 6, 2008, be suspended for the maximum period
RESOLUTION NO. R2008-46
allowed by law to permit adequate time to review the proposed changes and to
establish reasonable rates..
Section 2. That it is hereby officially found and determined that the meeting at
which this Resolution is passed is open to the public as required by law and the public
notice of the time, place, and purpose of said meeting was given as required.
Section 3. A copy of this Resolution shall be sent to CenterPoint, care of
Denise Hardcastle, Director of Regulatory Activities and Compliance, CenterPoint
Energy, P.O. Box 2628, Houston, Texas 77252-2528 and to Thomas Brocato, at Lloyd
Gosselink, P.C., 816 Congress, Avenue, Suite 1900, Austin, Texas 78701.
PASSED, APPROVED and ADOPTED this the 24th day of Mar ., 2008.
TOM REID
MAYOR
APPROVED AS TO FORM:
~ • ~ . ~.
DARRIN M. COKER
CITY ATTORNEY
2
Lloyd
i3 Congress:Avenue;Suite 1900,
Austin,Tqxit•78701
Gosselink TUlephone:(512)42-5E300
Fiesiruile:-(5 12)472:054
.
=41 ATTORNEYS A T W
www.Igliwfirm.com
attic*. pirea,Liriat (512.)322-5857-
$tept
MEMORANDUM
TO: Cities Served by'CenterPOintEnergy Entex,--.:Texas Coast Division
FROM: Geoffrey Gay
FebttiarY.29, 200-8
RE: UpeothingCeriterPoint Energy Entex's Rate Increase Request
The purpose of this-Memorandum is to.notify client cities that next week CenterPoint
. . •
Energy Will. filing an application to increase natural gas Service rates throughout its
Texas Coast Division Barring direction to do otherwise,we will quickly review the.filing and
prepare a rsummary memorandum and procedural guide for your Use. We will distribute that
material to you next week, along with.a model suppensionresolUtion.
According to information we have Obtained from.the, Company, they intend to file
statements of intent to increase rates on March..6,11NA With the Railroad Commission arid the 47
cities with original jurisdiction in the Texas Coast Division. The proposed rates- will reflect
uniform, division-wide.rates, charges and terms and conditions of Service for the cities. and
environs of the Texas Coast Division. At this time; the Company has not indicated the amount
of
theintrease.stinght or iniPadt.on customers'.
CenterPoint has made much of the Tact-that it,has net increased its rates in a number of
years-. However,in most of the cities that it serves, CenterPerint has had automatic adjustment
clauses in place that have allowed Tate inereases,without having to file,a full rate case with the.
eities. Thus,"its rates have'increased, but the Cities have not had the Opportunity, until now, to
determine whether changes in the cost of money, eXpenses, investment and:revenues justify
higherates.
You may recall that in the past, the Company has attempted to. negotiate a:favorable.
result with the least amount of opposition and then,attempt to force that result on all other parties
Who have jurisdiction and justiciable interest In particular, three years ago-in the Houston
Division, CenterVpiot prepared.a system-wide cost of'service case and then filed it only in the
City of Houaton. After reaching a settlement agreement with the city of Houston,'tenterPaint
filed the Settlement Agreement reached with the City of Houston with the rest of the cities in
Harris,.Fort Bend and Montgomery Counties and simultaneously filed it with the Railroad
Commission to implement the Same rates in the environs areas. As a result of the efforts of the
Montgomery County client cities and several client cities in Fort Bend and Harris COnnties, we
Were able to secure a settlement requiring future rate cases to be simultaneously filed in all cities,
.
on a system-wide basis.
Lloyd Gosselink Bipvins FtOctielie &Townsend, P.C.
Page 2
February 29,2008
Similarly, in the South and East Regions, CenterPoint prepared .system-wide cost of
service cases but filed only at the Railroad CommisSion. for increased rates in unincorporated
areas, knowing that it would have little to no opposition. The Commission Staff typically relies,
upon intervenor cities to do the Majority of the discovery.and develop most of the contested
isstieS. CenterPoint skated through the Commission process with little challenge and a three
hour hearing and got most of its request blessed, It then'filed in*cities with original jurisdiction
and tried to impose the environsrates of cities,
Given this, past history, we belieVe, it is particularly important .for the. Gulf Coast
Coalition of Cities to be involved in the ratemalcing nrocess., Towards that objective, once the
filing is made, we will obtain a copy and conduct a preliminary assessment Afterwards, we will
prepare a mernorandurn.surrimarizing our review and proposing a course of action,
. •
Assuming the Company makes its filing on March 6, the proposed rate increase will be
effective under the law on April JP,:2908, unless the effective date is. suspended by action Of
your city.coUndil. Suspending the effective date is-A right provided to cities pursuant to the Gas
Utility Regulatory Act.; .Essentially, suspension provides cities additional time (125 days from
the date of the original filing or 90 days from the effective date) to evaluate the proposed rate
increase request. If no action is taken by the city council to suspend the rate increase request
before the effective date or to enact a rate ordinance by the end of the suspension period, the rate
increase automatically becomes effective. Consequently, we will be recommending that your
city council suspend the effective date at its first available meeting following the filing of the
casein order to-investigate the Company's request. For.your convenience, we will prepare and
distribute next week a model resolution suspending the effe,CtiVe datel of the rate intrease,
.Because this is a ratemaking proceeding,cities are entitled to recovery of their reasonable
expenses associated with participation in this matter, Accordingly, if your city decides to
Investigate the Company's request, there should be no cost to'the city for the hiring of legal
counsel and consultants.
If you would like additional information, please feel free to contact Geoffrey Gay or
Thomas Brodato (5.12)322-5857.
•
2208\mm 080229
Lloy(i Gpsselink Blpyjns. Roctlpilp &Townsend,
Lloyd 816 Congress Avenue,Suite 1900
Austin,Texas'h370 I
k„ Goss elinic (512)122-5800
Facsimile:(512)417i-0532.
Ma"' ATTORNEYS AT LAW
www.Iglawfirm.com
NFL Gay's Difect :(512)32.25875
Email:"ggay@Iglakidirni.doin
March.11,2008
City of Friendswood
910 South Friendswood Drive
Friendswood,'Texas 77546
Re Professional,Services Agreement for work on CenterPoint Energy Gas
2008 Texas Coast Division Rate case;
Billing File Xurnber:2208-1
'Dear_ •
We want to express our appreciation for a further opportunity to work With the Gulf
Coast Coalition of Cities ("qccc- or "Coalition") As part of our routine in opening new
Platters, we provide clients with an engagement letter. The purpose of this letter is to set forth
our understanding of the legal services to be performed by us for this engagement and the baSiS
upon which we.Will be paid for.thoSe_services.
Terms of Engagement
This letter confirms that Lloyd GOSselink ("Firm") will represent-gccc with respect to •
the filing by CenterPoint Energy Resources Corp. d/b/a CeriterPOint Energy Entex and
CenterPoint Energy Texas Gas ("CenterPoint") to increase rates in its Texas Coast Division (the
"Matten.
It is understood .and agreed that this engagement is limited to the Matter, and our
acceptance of this engagement does not imply any undertaking to provide legal services other
than those set-forth in this letter..
Personnel Who Will Be Working on the Matter
I will be the senior attorney in charge of our representation and I will be working on the
Matter, but my work on specific issues will be limited Thomas Brocato will be the billing
Attorney and in charge of coordinating resources needed for representation of GCCC. You may
call, write, or e-mail either Thomas or me whenever you have any questions about the Matter.
Other'Firm personnel, including Firm lawyers and paralegals, will participate in the Matter if, in
our judgment,their participation is necessary or appropriate. This representation includes advice
and preparation of documents needed for members of the Coalition to fulfill their responsibilities
as regulators and to protect the- interests of Coalition members and their citizens before the
Railroad Commission and in courts on appeal regarding the gas rate filing made on or about.
March 6, 2008: The Firm's services in this Matter will be extended to all cities:served by
CenterPoint in the Texas Coast Division that pass resolutions authorizing participation with
OCCa
Lloyd Gosselink Blevins Rochelle &Townsend, P.C.
March I I,2008
Page
Legal Fees and Other Charges.
Our fees in the Matter will be based on the time spent by Firm personnel,primarily Firm
lawyers or paralegals, who participate in the hit&ter. We will charge for all time spent by such
personnel in the Matter in Increments of tenths.of an hour. We charge for time spent in activities
including but not limited to the following telephone and office conferences with clients,
representatives of clients, opposing counsel, consultants, And others, conferences among our
attorneys and paralegals; factual investigation, if needed; legal research; file management,
respending to requests from you that we provide information to you or your auditors; drafting
letters,memoranda,pleadings, and other documents, and travel, if heeded.
Legal fees and costs are difficult to estimate and in rate cases, vary with the number of
intervenors, cooperation of the utility in responding to discovery, and orders .of the Railroad
CoMrnission. Accordingly, we have made no commitment concerning the fees and charges that
will be necessary to resolve or complete the Matter, although we will Make every effort to
manage fees and costs by working efficiently and cost-effectively, It is understood that
reasonable rate.case expenses of cities are to be reinibursed by the regulated utility And that the
Firm is to fully document and justify its fees and expenses'and to submit them for scrutiny by
citiés,CenterPoint:andthe Railroad Cominission.
Other lawyers, paralegals and personnel may be assigned as necessary to achieve proper
staffing. We utilize briefing clerks,paralegals,file clerks and other support personnel to perform
those tasks not requiring the time of an attorney. Their time is billed at an amount determined by
the experience of;the individual. Rates May be adjusted annually and, if so, will be noted on
Your bill. We will submit all out-Of-pocket expenses incurred for reimbursement with no mark-
up. A listing of hourly charges for the individuals I regard as having any likelihood of billing for
services to GCCC on this matter in 2008 and a listing of standard office charges is attached as
Exhibit 1. We,endeavor to have a statement of services rendered and expenses incurred by the
15th of thefollowing month.
It is understood that the City of Friendswood will function as treasurer/billing agent for
this matter and that legal and consultant invoices will be tent to the City of Friendswood,for
review and submission to centerPoint for reimbursement, The Coalition may require that copies
of invoices by delivered to Coalition members .other than Friendswood. The City of
Friendswood assumes no liability or indenunfication because Of its services to GCCC and/or
acting as its agent.
Conflicts of Interest
Before accepting the Matter, we have undertaken reasonable and customary efforts to
determine whether there are any potential conflicts of interest that would bar our firm from
representing you in the Matter. We Make reasonable efforts to comply with the requirements of
Chapter 1 76 of the Texas Local Government Code and House Bill 1491, enacted by the 80th
Texas Legislature in 2007. We have performed an internal Conflict of interest inquiry. Based On
the information available to us, We are not aware of any potential disqualificatidn. We reviewed
that issue in accordance with the rules of professional responsibility adopted in.Texas.
Lloyd Gosselink Blevins Rochelle &Townsend, P.C.
March.11,2008
Page-3
Document Retention
Upon completion of our work on this matter, it is our firm'a- policy that original
documents belonging to any Coalition member and other client property be returned within
reasonable period of time. Our own files, including lawyer Work product pertaining to the
Matter, will be retained by the Firm, These Finn-files include Firm administrative records,time
and expense-reports, billing and accounting're-Cords, and internal work product.. Internal work
product includes drafts, notes, internal communications (in both paper and electronic mediums),
and legal and factual research prepared for the internal use of our firm's lawyers,: All documents
retained by the Firm will be transferred to the person.responsible for administering our records
retention program. For various reasons,: including the minimization of Unnecessary ‘storage
expenses, we reserve the.right to destroy or otherwise dispose of any such documents or other
materials retained by us after the completion of our work.
• Communication.and Confidentiality
In keeping with technological advancements and the corresponding demands of clients,it
is the practice of the Firm to use electronic (email) correspondence from time to time to
communicate and to transmit doeuments. The Firm employs several security measures to
prevent the interception of electronic transmissions and preserve Confidentiality. Still, the
possibility exists that electronic transmissions could be intercepted or otherwise received hy third
parties and lose their privileged nature if the method of communication is ruled to lack suffiCient.
confidentiality As with any correspondence regarding legal representation, regardless of the
Manner of'transmission, we urge the Coalition to use caution in its dissemination in order to
protect its confidentiality. By signing below, the:Coalition agrees that we May use email and a
client-Specifia'Web page in the scope-ofour representation of the Coalition,
Periodically, the Firm is asked to provide a "Representative Client List" to prospective
Clients and in various legal directories(e.g.,Martiticlalt4Inbbell and the Texas Legal DireetorY).
We would like confirmation that we May continue to disclose to third parties the.fact that the
Firm represents the 'OCCc. We ,are not requesting.authorization to disclose any privileged
information obtained during its representation By signing below the Coalition agrees that we
may reveal the fact that We represent the Co alitiont6 third parties..
The cope of the Representation:and'Termination
The scope Of employment under this agreement includes maintaining contact with
member cities through various means of communication including memoranda,,attendance at
meetings of members, conference calls and presentations when necessary to individual city
councils; monitoring and participating in proceedings related to the Matter at the.Railroad
Commission and the courts; advocating Coalition position:s. before administrative agencies, he
courts and the Legislature; strategic and legal guidance: to the Coalition; negotiations with
CenterPoint related to settlement;and other matters as may be mutually agreed. All activities are
subject to the discretion of the Coalition. The Coalition may demand an immediate halt to any
and all services at any point. Services under this Agreement may be terminated by either party at
any point by providing 48 hours written notice.
'Lloyd Go8elink Blevins Rochelle Townsend,
. ,
. .
March 11,-2008
.Fav 4
Cofichthion
This letter constitutes the entire terms of:the engagement of Lloyd dosselink in the
Matter. Unless expressly stated in these terms of engagement,no obligation or undertaking shall
be implied.on the part of either Ott C.or Lloyd GesSelinli.
If there are any questions. about these terms of engagement, or if theSe-: terms are
,..
unacceptable in any way,please Jet me know inanediatoly. If acceptable, we would appreciate
you signing and returning, on behalf of the Coalition,'the enclosed duplicate ,original of this
document.
- .
Sincerely,
4172 'r--7 g
,,,,, Geoff - M. Gay Tr)
. :0; . ..
Enclosure
APPROVED:
GULF COAST COALITION OF CITIES.
. .
Signature.
•
•
Printed Name
Date
220810 11410803 11 •
Lloyd Gossellnk Blevins Rochelle &Townsend, P.C.
•
Exhibit I
Schedule Of Fees for 2008
Geoffrey Gay $350
Thomas Brocato $255
Kristen Doyle $255
Georgia Crump $275
Chris Brewster $1175
Jessica Luparello $170
Paralegal $100
Of Counsel/Sr. Contract Attorney $270
• Schedule of Charges for 2008
Photocopies $.20/page
Telefax(sending only) $20/page
Messenger/ Clerical Delivery $10/hour
Scanning $ 15/page.
CD Burning or Duplication $5/CD
Lloyd Gosselink.BlevIns Rochelle & Townsend, P.C.