This Financing Order addresses the application of CenterPoint Energy Houston Electric, LLC (CenterPoint Houston) under PURA¹ chapter 36, subchapter I² and chapter 39 subchapter G.³ In its application, CenterPoint Houston seeks the following: (1) authorization of the issuance of system restoration bonds⁴ to securitize the system restoration costs and carrying costs approved by the Commission in Docket No. 57271,⁵ net of any insurance proceeds, government grants, and other sources of funding that have been received by CenterPoint Houston that compensate CenterPoint Houston for system restoration costs at the time of the application for this Financing Order (the securitizable balance); (2) to securitize certain other qualified costs incurred in connection with such securitization as further defined and described below; (3) approval of the proposed securitization financing structure; (4) approval of system restoration charges sufficient to recover the principal and interest on the system restoration bonds and to recover the ongoing qualified costs of supporting and servicing the system restoration bonds; (5) approval of the tariff to implement the system restoration charges; and (6) approval of the tariff to implement the accumulated deferred federal income tax credit (ADFIT Credit).

¹    Public Utility Regulatory Act, Tex. Util. Code §§ 11.001–66.016.

⁴    Under PURA § 36.403(e), “transition bonds” issued to securitize system restoration costs may be called “system restoration bonds.”

⁵    Application of CenterPoint Energy Houston Electric, LLC For Determination of System Restoration Costs, Docket No. 57271, Order (Apr. 24, 2025).

On November 8, 2024, CenterPoint Houston filed an application in Docket No. 57271 under PURA § 36.405 to quantify the reasonable and necessary system restoration costs incurred in connection with two storm events taking place in May 2024: a May 16, 2024 storm that the National Weather Service has officially named “the Houston Derecho” and a wave of strong thunderstorms that caused extensive damage in the Houston area on May 28, 2024 (collectively, the Storms). As discussed in this Financing Order, the Commission finds that CenterPoint Houston should be authorized to securitize and to cause the issuance of system restoration bonds in accordance with this Financing Order. The Commission also finds that the securitization approved in this Financing Order meets all applicable requirements of PURA.

In this Financing Order, the Commission approves the securitization of the sum of the Securitizable Balance plus up-front qualified costs as described in Ordering Paragraphs 1 and 16. The Commission also approves the structure of the proposed securitization financing and issuance of system restoration bonds in one or more series and approves system restoration charges in an amount to be calculated as provided in this Financing Order. The Commission further approves the form tariff to implement the system restoration charges and the form tariff to implement the ADFIT Credit. Finally, the Commission finds that the potential benefits of: (1) floating-rate system restoration bonds and interest-rate swaps within the securitization financing structure, (2) the issuance of system restoration bonds denominated in foreign currencies, and (3) the use of interest-rate hedges will not outweigh the incremental risk to customers. Therefore, the Commission concludes that floating-rate system restoration bonds and interest-rate swaps should not be utilized within the securitization financing structure and that CenterPoint Houston should not be authorized to issue system restoration bonds denominated in a foreign currency or use interest-rate hedges.

To approve the securitization of the system restoration costs, the Commission must consider whether the proposed securitization meets the financial tests set forth in PURA chapter 36, subchapter I and chapter 39, subchapter G. The three financial tests require that: (1) the total revenues collected under this Financing Order are less than the revenues collected using conventional financing methods (the total-revenues test),⁶ (2) the securitization of the system restoration costs provides greater tangible and quantifiable benefits to ratepayers⁷ than would have been achieved without the issuance of the system restoration bonds (the tangible-and-quantifiable-benefits test),⁸ and (3) the amount securitized does not exceed the present value of the revenue requirement over the life of the proposed system restoration bonds associated with the system restoration costs sought to be securitized (the present-value test).⁹

⁷    The term “customer” used throughout this financing order will encompass the term “ratepayer” as it is used throughout PURA §§ 36.401–.406 and §§ 39.301–.313.

CenterPoint Houston submitted evidence demonstrating that the proposed securitization will meet each of the financial tests set forth in PURA chapter 36, subchapter I and PURA chapter 39, subchapter G. All of the calculations performed by CenterPoint Houston demonstrated that the transaction would pass these tests. Considering the margin by which the proposed securitization passes the various tests, the Commission declines to determine a particular number for each benefit conferred by the proposed securitization. Accordingly, in quantifying the benefit to customers as a result of this securitization, the Commission refers to the ranges of benefits calculated under CenterPoint Houston’s expected-case scenario, in which the system restoration bonds bear a 4.90% weighted-average interest rate, and a sensitivity case-scenario, in which the system restoration bonds are subject to a 7.24% weighted-average interest rate.

CenterPoint Houston’s evidence showed that, as a result of the securitization approved by this Financing Order, retail customers served at distribution voltage in CenterPoint Houston’s service area (customers) will realize benefits. Based on the amount that CenterPoint Houston seeks to securitize, CenterPoint Houston’s financial analysis indicated that, for the tangible-and-quantifiable-benefits test, such customers will realize benefits estimated to be $85,000 on a present-value basis in the sensitivity-case scenario. At the expected weighted-average interest rate of 4.90%, securitization confers benefits of $63 million on a present-value basis. In addition, under the sensitivity-case scenario, the securitization will result in a reduction in the amount of revenues collected by CenterPoint Houston of $76,000, on a nominal basis, when compared to the amount that would have been collected under the conventional financing methods that would otherwise be used to recover the system restoration costs. In the expected case, the securitization will result in a reduction in the amount of revenues collected by CenterPoint Houston of $88 million, on a nominal basis. Finally, under the present-value test, the present value of the amount CenterPoint Houston initially sought to securitize—$408.5 million in the expected case and $407.5 million in the 7.24% sensitivity case—does not exceed the present value of the revenue requirements using conventional financing. Accordingly, the Commission concludes that the benefits for customers set forth in CenterPoint Houston’s evidence are fully indicative of the benefits that customers will realize from the securitization approved here. In the issuance advice letter, CenterPoint Houston will be required to update the benefit analyses to verify that the final structure of the securitization satisfies the statutory financial tests.

CenterPoint Houston provided a general description of the proposed securitization transaction structure in its application and in the testimony and exhibits submitted in support of its application. The proposed securitization transaction structure does not contain every relevant detail and, in certain places, uses only approximations of certain costs and requirements. The final securitization transaction structure will depend, in part, upon the requirements of the nationally-recognized credit rating agencies that will rate the system restoration bonds and, in part, upon the market conditions that exist at the time the system restoration bonds are taken to the market.

While the Commission recognizes the need for some degree of flexibility with regard to the final details of the securitization transaction approved in this Financing Order, its primary focus is upon the statutory requirements—the most important of which is to ensure that securitization results in tangible and quantifiable benefits to customers—that must be met before issuing a financing order.

In view of these obligations, the Commission has established certain criteria in this Financing Order that must be met in order for the approvals and authorizations granted in this Financing Order to become effective. This Financing Order grants authority to issue system restoration bonds and to impose, collect, and receive system restoration charges only if the final structure of the securitization transaction complies in all material respects with these criteria. The authority and approval granted in this Financing Order is effective only upon CenterPoint Houston filing with the Commission an issuance advice letter demonstrating compliance of that issuance with the provisions of this Financing Order. If market conditions make it desirable to issue the system restoration bonds in more than one series, then the authority and approval in this Financing Order is effective as to each issuance, but only upon CenterPoint Houston filing with the Commission a separate issuance advice letter for that issuance demonstrating compliance with the provisions of this Financing Order.

The Texas Legislature amended PURA in 2009 to permit electric utilities to use securitization financing to recover costs of restoring service and infrastructure associated with electric power outages as a result of hurricanes and other weather-related events or natural disasters that occurred in 2008 or later.¹⁰ The Legislature provided this option for recovering qualified costs based on the conclusion that securitization financing will lower the carrying costs associated with recovery of these costs relative to the costs that would be incurred using conventional utility financing methods.¹¹ As a precondition to the use of securitization, the Legislature required that the Commission must ensure that the securitization will provide greater tangible and quantifiable benefits to customers than would have been achieved without the issuance of the system restoration bonds.¹² Consequently, a basic purpose of securitization financing—the recovery of an electric utility’s qualified costs—is conditioned upon the other basic purpose—providing economic benefits to consumers of electricity in this state. The provisions for securitization of system restoration costs were based on and incorporate relevant terms of the provisions in chapter 39, subchapter G of PURA for securitization of transition costs adopted by the Texas Legislature in 1999, which have been used by CenterPoint Houston and other electric utilities to reduce the costs of recovering costs associated with the transition to competition.¹³

Under chapter 36, subchapter I of PURA, the qualified costs eligible for securitization by CenterPoint Houston include: (1) the system restoration costs determined by the Commission in Docket No. 57271 (the proceeding to determine the amount of CenterPoint Houston’s system restoration costs eligible for recovery and securitization), net of any insurance proceeds, government grants, or other sources of funding that compensate CenterPoint Houston for system restoration costs incurred by CenterPoint Houston at the time of the application for this Financing Order, with carrying costs on the unrecovered balance at CenterPoint Houston’s weighted average cost of capital as approved in its last rate case; (2) costs of issuing, supporting and servicing the system restoration bonds and any costs of retiring and refunding existing debt and equity securities; (3) costs to the Commission of acquiring professional services for the purposes of evaluating the proposed securitization transaction; and (4) costs associated with ancillary agreements such as bond insurance policies, letters of credit, reserve accounts, surety bonds, swap arrangements, hedging arrangements, liquidity or credit support arrangements, or other financial arrangements entered into in connection with the issuance or payment of the transition bonds.¹⁴ Chapter 36, subchapter I of PURA also expressly provides: (1) that the term transition bonds, as defined and used in chapter 39, subchapter G of PURA, includes bonds issued under chapter 36 (i.e. system restoration bonds),¹⁵ (2) that the term transition charges, as defined and used in subchapter G, includes all non-bypassable amounts approved by the Commission under a financing order to recover system restoration costs (i.e. system restoration charges),¹⁶ (3) the term financing order as defined and used in chapter 39, subchapter G of PURA, includes a financing order authorizing the securitization of system restoration costs, and (4) that the provisions of chapter 39, subchapter G of PURA (i.e., the provisions with respect to the issuances of system restoration bonds, the imposition of system restoration charges, and the creation of transition property (system restoration property))¹⁷ must govern financing orders allowing for securitization of system restoration costs and all rights and interests established in such order, except to the extent that such provisions conflict with the provisions of PURA chapter 36, subchapter I, in which case the latter provisions must control.¹⁸

¹³ See, e.g., Application of CenterPoint Energy Houston Electric, LLC for Financing Order, Docket No. 30485, Financing Order (Mar. 16, 2005); Application of AEP Texas Central Company for a Financing Order, Docket No. 32475, Financing Order (June 21, 2006); Application of CenterPoint Energy Houston Electric, LLC for Financing Order, Docket No. 34448, Financing Order (Sept. 18, 2007); Application of AEP Texas Inc. for a Financing Order, Docket No. 49308, Financing Order (June 17, 2019); Application of Entergy Texas, Inc for a Financing Order; Docket No. 52302, Order (Jan. 14, 2022).

¹⁷    The term “system restoration property” used throughout this financing order will have the full effect as “transition property” as defined under PURA § 39.302(8) and used throughout PURA §§ 36.401–.406.

To allow for securitization of an electric utility’s qualified costs associated with system restoration costs, the Commission may authorize the issuance of system restoration bonds. System restoration bonds are generally defined as evidences of indebtedness or ownership that are issued under a financing order, are limited to a term of not longer than 15 years, and are secured by or payable from system restoration property, which includes all rights and interests of an electric utility under a financing order at the time such rights are transferred to an assignee or pledged in connection with the issuance of system restoration bonds.¹⁹ The net proceeds from the sale of system restoration bonds must be used to reduce the amount of a utility’s recoverable system restoration costs.²⁰ If system restoration bonds are approved and issued, retail electric customers must pay the principal, interest, and related charges of the system restoration bonds through system restoration charges.²¹ System restoration charges are non-bypassable charges that will be paid as a component of the monthly charge for electric service.²² System restoration charges must be approved by the Commission under a financing order.²³

The Commission may adopt a financing order only if it finds that the total amount of revenues to be collected under the financing order is less than the revenue requirement that would be recovered using conventional financing methods and that the financing order is in accordance with the standards of PURA §§ 36.401 and 39.301.²⁴ The Commission must ensure that the net proceeds of system restoration bonds may be used only for the purpose of reducing the amount of recoverable system restoration costs.²⁵ In addition, the Commission must ensure that: (1) securitization provides tangible and quantifiable benefits to customers greater than would have been achieved absent the issuance of the system restoration bonds,²⁶ and (2) the structuring and pricing of the system restoration bonds result in the lowest system-restoration-bond charges in compliance with market conditions and the terms of a financing order.²⁷ Finally, the amount securitized may not exceed the present value of the revenue requirement over the life of the proposed system restoration bonds associated with the amounts sought to be securitized, and the present value calculation must use a discount rate equal to the proposed interest rate on the system restoration bonds.²⁸ All of these statutory requirements are designed to ensure that securitization will provide real benefits to retail customers.

The essential finding by the Commission that is needed to issue a financing order is that customers will receive tangible and quantifiable benefits as a result of securitization. This finding can only be made upon a showing of economic benefits to customers through an economic analysis. An economic analysis is necessary to recognize the time value of money in evaluating whether and the extent to which benefits accrue from securitization. Moreover, an economic analysis recognizes the concept that the timing of a payment can be as important as the magnitude of a payment in determining the value of the payment. Thus, an analysis showing an economic benefit is necessary to quantify a tangible benefit to customers.

Economic benefits also depend upon a favorable financial market—one in which system restoration bonds may be sold at an interest rate lower than the carrying costs of the assets being securitized. The precise interest rate at which system restoration bonds can be sold in a future market, however, is not known today. Nevertheless, benefits can be calculated based upon certain known facts (e.g., the amount of system restoration costs to be securitized and the cost of the alternative to securitization) and assumptions (e.g., the interest rate of the system restoration bonds, the term of the system restoration bonds, and the amount of other qualified costs). By analyzing the proposed securitization based upon those facts and assumptions, a determination can be made as to whether tangible and quantifiable benefits result. To ensure that benefits are realized, the securitization transaction must conform to the structure ordered by the Commission and an issuance advice letter must be presented to the Commission immediately before issuance of the system restoration bonds demonstrating that the actual structure and costs of the system restoration bonds will provide tangible and quantifiable benefits. The cost-benefit analysis contained in the issuance advice letter must reflect the actual structure of the system restoration bonds.

CenterPoint Houston’s financial analysis shows that securitizing the Securitizable Balance along with CenterPoint Houston’s other qualified costs in the manner provided by this Financing Order will produce an economic benefit to customers of $63 million on a present value basis using the expected weighted-average interest rate of 4.90%. A benefit of $85,000 will result even if the bond market is less favorable than current market conditions and system restoration bonds have to be issued at the sensitivity-case weighted-average interest rate of 7.24%.²⁹ The economic benefit to customers will be larger if a more favorable market allows the system restoration bonds to be issued at a lower interest rate. In the issuance advice letter, CenterPoint Houston will be required to update the benefit analyses to verify that the final system restoration bond structure and pricing satisfies the statutory financial tests.

To issue a financing order, PURA also requires that the Commission find that the total amount of revenues collected under the financing order will be less than would otherwise have been collected under conventional financing methods.³⁰ In this proceeding, CenterPoint Houston’s financial analysis of the amount sought to be securitized under sensitivity-case market conditions, in which the system restoration bonds bear a 7.24% weighted average interest rate, demonstrates that revenues will be reduced by $76,000 on a nominal basis under this Financing Order compared to the amount that would be recovered under conventional financing methods. Under the base-case scenario in which the system restoration bonds are issued at a 4.90% weighted average annual interest rate, securitization saves customers $88 million in nominal revenue.³¹ If system restoration bonds are issued in a more favorable market, this reduction in revenues will be larger.

Before the system restoration bonds may be issued, CenterPoint Houston must submit to the Commission an issuance advice letter in which it demonstrates, based upon the actual market conditions at the time of pricing, that the proposed structure and pricing of the system restoration bonds will provide real economic benefits to customers and comply with the statutory financial tests and terms of this Financing Order. As part of this submission, CenterPoint Houston must also certify to the Commission that the structure and pricing of the system restoration bonds result in the lowest system-restoration-bond charges in compliance with market conditions at the time of pricing and the terms of this Financing Order. The form of certification that must be submitted by CenterPoint Houston is set out in appendix A to this Financing Order. The Commission, by order, may stop the issuance of the system restoration bonds authorized by this Financing Order if CenterPoint Houston fails to make this demonstration or certification.

PURA requires that system restoration charges be charged for the use or availability of electric services to recover all qualified costs.³² System restoration charges, like transition charges, can be recovered over a period that does not exceed 15 years.³³ The Commission concludes that this prevents the collection of system restoration charges from customers for services rendered after the 15-year period but does not prohibit recovery of system restoration charges for service rendered during the 15-year period but not actually collected until after the 15-year period.

System restoration charges constitute transition charges as defined in PURA § §39.302 and used in chapter 39, subchapter G of PURA³⁴ and will be collected by an electric utility, its successors, an assignee, or other collection agents as provided for in this Financing Order.³⁵ System restoration charges must be functionalized and allocated to customers in the same manner as the corresponding facilities relating to the system restoration costs and related expenses are functionalized and allocated in a utility’s current base rates.³⁶ The Commission further determines that, to ensure that the allocation of system restoration charges are functionalized in such manner, the ADFIT benefits associated with the securitization transaction should be calculated and allocated in the manner described in this Financing Order.

The rights to impose, collect, and receive system restoration charges (including all other rights of an electric utility under the financing order) are only contract rights until such rights are first transferred to an assignee or pledged in connection with the issuance of system restoration bonds.³⁷ Upon the transfer or pledge of those rights, they become system restoration property and, as such, are afforded certain statutory protections to ensure that the system restoration charges are available for system restoration bond retirement.³⁸

This Financing Order contains terms, as it must, ensuring that the imposition and collection of system restoration charges authorized herein must be non-bypassable.³⁹ It also includes a mechanism requiring that system restoration charges be reviewed and adjusted at least annually, within 45 days of the anniversary date of the issuance of the system restoration bonds, to correct any overcollections or undercollections during the preceding 12 months and to ensure the expected recovery of amounts sufficient to timely provide all payments of debt service and other required amounts and charges in connection with the system restoration bonds.⁴⁰ In addition to the required annual reviews, interim reviews are allowed to ensure that the amount of the system restoration charges matches the funding requirements approved in this Financing Order. These provisions will help to ensure that the amount of system restoration charges paid by customers does not exceed the amount necessary to cover the costs of this securitization. To encourage utilities to undertake securitization financing, other benefits and assurances are provided.

The State of Texas has pledged, for the benefit and protection of financing parties and electric utilities, that it will not take or permit any action that would impair the value of system restoration property, or, except for the true-up expressly allowed by law, reduce, alter, or impair the system restoration charges to be imposed, collected, and remitted to financing parties, until the principal, interest, and any other charges incurred and contracts to be performed in connection with the related system restoration bonds have been paid and performed in full.⁴¹

System restoration property (whether associated with a single system restoration bond issuance covering the entire amount of system restoration costs authorized to be financed with securitization or with one of multiple system restoration bond issuances, with each issuance covering only a portion of the total amount authorized to be securitized) constitutes a present system restoration property right for purposes of contracts concerning the sale or pledge of property, and the property will continue to exist for the duration of the pledge of the State of Texas as described in the preceding paragraph.⁴² In addition, the interests of an assignee or pledgee in system restoration property (as well as the revenues and collections arising from the system restoration property) are not subject to setoff, counterclaim, surcharge, or defense by the electric utility or any other person or in connection with the bankruptcy of the electric utility or any other entity.⁴³ Further, transactions involving the transfer and ownership of system restoration property and the receipt of system restoration charges are exempt from state and local income, sales, franchise, gross receipts, and other taxes or similar charges.⁴⁴ The creation, granting, perfection, and enforcement of liens and security interests in system restoration property are governed by PURA § 39.309 and not by the Texas Business and Commerce Code.⁴⁵

The Commission may, at the request of an electric utility, adopt a financing order providing for the retiring and refunding of system restoration bonds only upon making a finding that the future system restoration charges required to service the new system restoration bonds, including transaction costs, will be less than the future system restoration charges required to service the system restoration bonds being retired or refunded.⁴⁶ CenterPoint Houston has not requested, and this Financing Order does not grant, any authority to refinance the system restoration bonds authorized by this Financing Order. This Financing Order does not preclude CenterPoint Houston from filing a request for a financing order to retire or refund the system restoration bonds approved in this Financing Order upon a showing that the statutory criteria in PURA § 39.303(g) are met.⁴⁷

To facilitate compliance and consistency with applicable statutory provisions, this Financing Order adopts the definitions in PURA §§ 36.403 and 39.302.

II.            Description of Proposed Securitization Transaction

A description of the securitization transaction proposed by CenterPoint Houston is contained in its application and the filing package submitted in support of the application. A brief summary of the proposed securitization transaction is provided in this section. A more detailed description is included in the section III.C, titled Structure of the Proposed Securitization and in the application and filing package submitted in support of the application.

To facilitate the proposed securitization, CenterPoint Houston has proposed that (depending on whether more than one series of system restoration bonds are issued) one or more special purpose securitization funding entities (each referred to as BondCo) be created to which CenterPoint Houston will transfer the rights to impose, collect, and receive system restoration charges along with the other rights arising under this Financing Order, in each case allocable to the series of system restoration bonds the BondCo is issuing. Upon transfer to a BondCo (in connection with the issuance of the particular series of system restoration bonds), these rights will become system restoration property as provided by PURA § 39.304.⁴⁸ If system restoration bonds are issued in more than one series, then the system restoration property transferred as a result of each issuance must be only those rights associated with that portion of the total amount authorized to be securitized by this Financing Order which is securitized by a particular system restoration bond issuance. The rights to impose, collect and receive system restoration charges, along with the other rights arising under this Financing Order as they relate to any portion of the total amount authorized to be securitized that remains unsecuritized, must remain with CenterPoint Houston and must not become system restoration property until transferred to a BondCo in connection with a subsequent issuance of system restoration bonds.

CenterPoint Houston will create a separate BondCo for the issuance of a particular series of the system restoration bonds, and the rights, obligations, structure, and restrictions described in this Financing Order with respect to BondCo are applicable to each such purchaser of system restoration property to the extent of the system restoration property transferred and sold to it and the system restoration bonds issued by it. BondCo will issue system restoration bonds and will transfer the net proceeds from the sale of the system restoration bonds to CenterPoint Houston in consideration for the transfer of the corresponding system restoration property. BondCo will be organized and managed in a manner designed to achieve the objective of maintaining BondCo as a bankruptcy-remote entity that would not be affected by the bankruptcy of CenterPoint Houston or any other affiliates of CenterPoint Houston or any of their respective successors. In addition, BondCo will have at least one independent manager whose approval will be required for certain major actions or organizational changes by BondCo.

The system restoration bonds will be issued under an indenture and administered by an indenture trustee.⁴⁹ The system restoration bonds will be secured by and payable solely out of the system restoration property created under this Financing Order and other collateral described in CenterPoint Houston’s application. That collateral will be pledged to the indenture trustee for the benefit of the holders of the system restoration bonds and to secure payment of certain qualified costs.

The servicer of the system restoration bonds will collect the system restoration charges and remit those amounts to the indenture trustee on behalf of BondCo. The servicer will be responsible for filing any required or allowed true-ups of the system restoration charges. If the servicer defaults on its obligations under the servicing agreement, the indenture trustee may, on behalf of the holders of system restoration bonds, appoint a successor servicer. CenterPoint Houston will act as the initial servicer for the system restoration bonds.

⁴⁹    If more than one series of system restoration bonds is issued, each series will be issued under a separate indenture and be subject to its own set of basic agreements (e.g., system restoration property purchase and sale agreement, system restoration property servicing agreement, administration agreement). For purposes of this Financing Order, the description of the system restoration bonds applies to each series of system restoration bonds.

Retail electric providers (REPs) will be required to meet certain financial standards to collect system restoration charges under this Financing Order. If a REP qualifies to collect system restoration charges, the servicer will bill to and collect from the REP the system restoration charges attributable to the REP’s customers. The REP in turn will bill to and collect from its customers the system restoration charges attributable to them. If any REP fails to qualify to collect system restoration charges or defaults in the remittance of those charges to the servicer of the system restoration bonds, another entity can assume responsibility for collection of the system restoration charges from the REP’s customers.

System restoration charges will be calculated to ensure the collection of an amount sufficient to service the principal, interest, and related charges for the system restoration bonds. The costs will be functionalized and allocated in the same manner as corresponding facilities and related expenses are functionalized and allocated in CenterPoint Houston’s current base-rates.⁵⁰ The system restoration charges will be calculated by the method described in Schedule SRC – System Restoration Charges (Schedule SRC), a pro forma copy of which is contained in appendix B. In addition to the annual true-up required by PURA § 39.307, interim true-ups may be performed as necessary to ensure that the amount collected from system restoration charges is sufficient to service the system restoration bonds. In addition, an adjustment to the system restoration charge class allocations will be allowed under certain circumstances. The methodology for making true-ups and class allocation adjustments and the circumstances under which each must be made are described in Schedule SRC.

The Commission determines that CenterPoint Houston’s proposed system restoration charge structure should be utilized. This structure, which was used in each of CenterPoint Houston’s prior securitizations, is designed to produce essentially level residential rates over the recovery period if: (1) the actual year-to-year changes in customers’ loads match the changes forecasted at the time the system restoration bonds are structured and (2) annual loads and costs match those used to develop each system restoration charge true-up. If the system restoration bonds are issued in more than one series, the system restoration charges for each series must provide a substantially level system restoration charge structure.

All of the transition bonds and system restoration bonds issued in prior Texas securitizations have been issued with a fixed interest rate.⁵¹ A fixed interest rate is necessary to assure that customers benefit from the securitization. Although the benefits of fixed rates can be achieved through a combination of floating-rate bonds and interest-rate swaps, the Commission in prior securitizations in Texas concluded that the possible benefit of floating-rate bonds did not outweigh the cost of preparing for and executing interest-rate swaps and the potential risks swaps would impose on retail customers. As a result, the financing orders in those proceedings prohibited the use of interest-rate swaps and thus, effectively, the issuance of floating-rate bonds. The Commission reaches the same conclusion in this proceeding and prohibits CenterPoint Houston from issuing floating-rate system restoration bonds.

The Commission reaches a similar conclusion that issuance of system restoration bonds denominated in foreign currency should likewise be prohibited. Denominating system restoration bonds in foreign currency would create foreign currency risks for customers. While these risks can be reduced through use of derivatives, the derivatives themselves create risks for customers.

Interest-rate hedges can also be used to lock in interest rates or limit the variability of interest rates before issuance of the system restoration bonds. However, the hedge is a bet on the direction of future market changes, which is neither necessary nor appropriate. Hedges also create additional costs and risks if, for any reason, the system restoration bonds are not issued or the amount issued is different from the principal amount hedged. As a result, this Financing Order prohibits CenterPoint Houston from issuing system restoration bonds denominated in foreign currencies and from entering into interest-rate hedges.

CenterPoint Houston requested approval of system restoration charges sufficient to recover the principal and interest on the system restoration bonds plus ongoing qualified costs of supporting and servicing the system restoration bonds as described in this Financing Order and appendix C. CenterPoint Houston requested that the system restoration charges be recovered from REPs, and through them from consumers, and that the amount of the system restoration charges be calculated based upon the allocation methodology and billing determinants specified in Schedule SRC. CenterPoint Houston also requested that certain standards related to the billing and collection of system restoration charges be applied to REPs, as specified in Schedule SRC. To implement the system restoration charges and billing and collection requirements, CenterPoint Houston requested approval of Schedule SRC.

⁵¹    E.g., Application of AEP Texas Central Company for a Financing Order, Docket No. 32475, Financing Order at 14 and 15 (June 21, 2006); Application of Entergy Gulf States, Inc. for a Financing Order, Docket No. 33586, Financing Order at 2 (Apr. 2, 2007); Application of CenterPoint Houston Electric, LLC for a Financing Order, Docket No. 34448, Financing Order at 2 (Sep. 18, 2007); Application of CenterPoint for a Financing Order, Docket No. 37200, Financing Order at 2 (Aug. 27, 2009); Application of Entergy Texas, Inc. for a Financing Order, Docket No. 37247, Financing Order at 2 (Sept. 11, 2009); Application of AEP Texas Central Company for a Financing Order, Docket No. 39931, Financing Order at 16 (June 17, 2019); Application of Entergy Texas, Inc. for a Financing Order, Docket No. 52302, Order at 15 (Jan. 14, 2022).

CenterPoint Houston requested authority to securitize and to cause the issuance of system restoration bonds in an aggregate principal amount not to exceed the sum of: (1) the Securitizable Balance at the date of issuance of the system restoration bonds plus (2) its actual up-front qualified costs of issuing, supporting, and servicing the system restoration bonds. CenterPoint Houston provided an illustrative analysis of the costs and benefits of securitization using its estimate of the September 2, 2025 Securitizable Balance. CenterPoint Houston proposed that these amounts be updated in the issuance advice letter to reflect the actual issuance date of the system restoration bonds and other relevant current information as permitted by this Financing Order, and that CenterPoint Houston be authorized to securitize the updated Securitizable Balance and up-front qualified costs as reflected in the issuance advice letter.

CenterPoint Houston requested in the application that its up-front and ongoing costs of issuing and maintaining the system restoration bonds be recovered respectively through the system restoration bonds and system restoration charges approved in this Financing Order. CenterPoint Houston estimated that its up-front costs would total $5.2 million, while its ongoing costs of servicing the system restoration bonds would total $700,000 per year for each year of the term of the system restoration bonds. The estimates were based on assumptions regarding a number of variables that will directly affect the level of up-front and ongoing qualified costs including the following: (1) the total Securitizable Balance will be $396 million; (2) only one series of system restoration bonds will be issued; (3) the financing order proceeding will not be contested; (4) the financing order will not permit use of interest-rate or foreign-currency hedges, floating-rate system restoration bonds, or system restoration bonds denominated in foreign currencies; and (5) CenterPoint Houston will act as the servicer.

The Commission finds that CenterPoint Houston should be permitted to securitize its up-front costs of issuance in accordance with the terms of this Financing Order. In the issuance advice letter, CenterPoint Houston must report the actual qualified costs securitized.

CenterPoint Houston is authorized to recover directly through the system restoration charges its actual ongoing costs of servicing the system restoration bonds and providing administration services to BondCo, subject to a cap on annual servicing fees equal to 0.075% of the initial principal amount of system restoration bonds issued under this Financing Order and a cap on annual administrative fees of $100,000 for each BondCo plus reimbursable third-party costs, which will apply as long as CenterPoint Houston continues to serve as the servicer or administrator, respectively. Ongoing qualified costs, other than the servicer and administrative fees charged by CenterPoint Houston when it is the servicer and administrator, are not capped. They are, however, estimated in appendix C. The estimated ongoing qualified costs should be updated in the issuance advice letter to reflect more current information then available to CenterPoint Houston. In accordance with the terms of this Financing Order and subject to the approval of the indenture trustee, the Commission will permit a successor servicer to CenterPoint Houston to recover a higher servicer fee if CenterPoint Houston ceases to service the system restoration bonds.

CenterPoint Houston does not anticipate incurring costs of refinancing or retiring debt or equity in connection with the use of the proceeds from the issuance of the system restoration bonds.⁵² However, if costs of refinancing or retiring debt or equity are incurred, the Commission notes that the cost of refinancing or retiring CenterPoint Houston’s existing debt or equity using the proceeds from the system restoration bonds must remain uncapped. Commission experience with these expenses indicates that they vary widely and are not entirely within CenterPoint Houston’s control. CenterPoint Houston should be authorized to record such costs as a regulatory asset included on its balance sheet and to accrue carrying costs on such regulatory asset using the average weighted interest rate on the system restoration bonds, until the costs are included in CenterPoint Houston’s next base-rate case, and that the costs, together with carrying costs, be evaluated for recovery in CenterPoint Houston’s next base-rate case, subject to a showing that such costs were prudently incurred and are reasonable and necessary.

⁵³    Application of CenterPoint Energy Houston Electric, LLC, for Authority to Change Rates, Docket No. 56211, Order (Mar. 13, 2025).

⁵⁷    E.g., Application of AEP Texas Central Company for a Financing Order, Docket No. 32475, Financing Order at 14–15 (June 21, 2006); Application of Entergy Gulf States, Inc. for a Financing Order, Docket No. 33586, Financing Order at 2 (Apr. 2, 2007); Application of CenterPoint Houston Electric, LLC for a Financing Order, Docket No. 34448, Financing Order at 2 (Sept. 18, 2007); Application of CenterPoint for a Financing Order, Docket No. 37200, Financing Order at 2 (Aug. 27, 2009); Application of Entergy Texas, Inc. for a Financing Order, Docket No. 37247, Financing Order at 2 (Sept. 11, 2009); Application of AEP Texas Central Company for a Financing Order, Docket No. 39931, Financing Order at 4 (Jan. 12, 2012); Application of Entergy Texas Inc, for a Financing Order, Docket No. 52302, Order at 15 (Jan. 14, 2022).

⁵⁸    The term assignee means any individual, corporation, or other legally recognized entity to which an interest in system restoration property is transferred, other than as security, including any assignee of that party. See PURA § 39.302(1).

a.            Rating, Deposit, and Related Requirements.

Each REP must (1) have a long-term, unsecured credit rating of not less than “BBB-” and “Baa3” (or the equivalent) from Standard & Poor’s and Moody’s Investors Service, respectively, or (2) provide to the indenture trustee (i) a deposit of two months’ maximum expected system-restoration-charge collections in the form of cash, (ii) an affiliate guarantee, surety bond, or letter of credit providing for payment of such amount of system restoration charge collections in the event that the REP defaults in its payment obligations, or (iii) a combination of any of the foregoing. A REP that does not have or maintain the requisite long-term, unsecured credit rating may select which alternate form of deposit, credit support, or combination thereof it will utilize, in its sole discretion. The indenture trustee must be a beneficiary of any affiliate guarantee, surety bond, or letter of credit. The provider of any affiliate guarantee, surety bond, or letter of credit must have and maintain a long-term, unsecured credit rating of not less than “BBB-” and “Baa3” (or the equivalent) from Standard & Poor’s and Moody’s Investors Service, respectively.

If the long-term, unsecured credit rating from either Standard & Poor’s or Moody’s Investors Service of a REP that did not previously provide the alternate form of deposit, credit support, or combination thereof or of any provider of an affiliate guarantee, surety bond, or letter of credit is suspended, withdrawn, or downgraded below BBB- or Baa3 (or the equivalent), the REP must provide the alternate form of deposit, credit support, or combination thereof, or new forms thereof, in each case from providers with the requisite ratings, within ten business days following such suspension, withdrawal, or downgrade. A REP failing to make such provision must comply with the provisions set forth in paragraph (e).

The computation of the size of a deposit required under paragraph (a) must be agreed upon by the servicer and the REP and reviewed no more frequently than quarterly to ensure that the deposit accurately reflects two months’ maximum expected system restoration charge collections. Within ten business days following such review, (1) the REP must remit to the indenture trustee the amount of any shortfall in such required deposit or (2) the servicer must instruct the indenture trustee to remit to the REP any amount in excess of such required deposit. A REP failing to so remit any such shortfall must comply with the provisions set forth in paragraph (e). REP cash deposits must be held by the indenture trustee, maintained in a segregated account, and invested in short-term high-quality investments, as permitted by the rating agencies rating the system restoration bonds. Investment earnings on REP cash deposits must be considered part of such cash deposits so long as they remain on deposit with the indenture trustee. At the instruction of the servicer, cash deposits will be remitted with investment earnings to the REP at the end of the term of the system restoration bonds unless otherwise utilized for the payment of the REP’s obligations for system restoration charges. Once the deposit is no longer required, the servicer must promptly (but not later than 30 calendar days) instruct the indenture trustee to remit the amounts in the segregated accounts to the REP.

d.            Payment of System Restoration Charges.

Payments of system restoration charges are due 35 calendar days following each billing by the servicer to the REP, without regard to whether or when the REP receives payment from its retail customers. The servicer must accept payment by electronic funds transfer, wire transfer, check, or any combination thereof. Payment will be considered received the date the electronic funds transfer or wire transfer is received by the servicer, or the date the check clears. A 5% penalty is to be charged on amounts received after 35 calendar days; however, a ten-calendar-day grace period will be allowed before the REP is considered to be in default. A REP in default must comply with the provisions set forth in paragraph (e). The 5% penalty will be a one-time assessment measured against the current amount overdue from the REP to the servicer. The current amount consists of the total unpaid system restoration charges existing on the 36th calendar day after billing by the servicer. Any and all such penalty payments will be made to the servicer to be applied against system restoration charge obligations. A REP must not be obligated to pay the overdue system restoration charges of another REP. If a REP agrees to assume the responsibility for the payment of overdue system restoration charges as a condition of receiving the customers of another REP that has decided to terminate service to those customers for any reason, the new REP must not be assessed the 5% penalty upon such system restoration charges; however, the prior REP must not be relieved of the previously assessed penalties.

After the ten calendar-day grace period (the 45th calendar day after the billing date) referred to in paragraph (d), the servicer must have the option to seek recourse against any cash deposit, affiliate guarantee, surety bond, letter of credit, or combination thereof provided by the REP, and avail itself of such legal remedies as may be appropriate to collect any remaining unpaid system restoration charges and associated penalties due the servicer after the application of the REP’s deposit or alternate form of credit support. In addition, a REP that is in default with respect to the requirements set forth in paragraphs (b), (c), or (d) above must, subject to the limitations and requirements of applicable bankruptcy laws if the REP is a debtor in bankruptcy, select and implement one of the following options:

If a REP that is in default fails to immediately select and implement one of the foregoing options or, after so selecting one of the foregoing options, fails to adequately meet its responsibilities thereunder, then the servicer must immediately implement option (i), subject to the limitations and requirements of applicable bankruptcy laws if the REP is a debtor in bankruptcy. Upon re-establishment of compliance with the requirements set forth in paragraphs (b), (c), and (d) above and the payment of all past-due amounts and associated penalties, the REP will no longer be required to comply with this paragraph.

Any interest that a REP (including the POLR) may have in any funds in the hands of the servicer must be junior and subordinate to any and all rights of the indenture trustee or BondCo to such funds.

The POLR appointed by the Commission must meet the minimum credit rating or deposit and credit support requirements described in paragraph (a) in addition to any other standards that may be adopted by the Commission. If the POLR defaults or is not eligible to provide such services, responsibility for billing and collection of system restoration charges will immediately be transferred to and assumed by the servicer until a new POLR can be named by the Commission or the customer requests the services of a certified REP. Customers may never be re-billed by the successor REP, the POLR, or the servicer for any amount of system restoration charges they have paid their REP (although future system restoration charges must reflect REP and other system-wide charge-offs). Additionally, if the amount of the penalty detailed in paragraph (d) is the sole remaining past-due amount after the 45th calendar day, the REP must not be required to comply with clauses (i), (ii), or (iii) of paragraph (e) above, unless the penalty is not paid within an additional 30 calendar days.

In the event that a REP disputes any amount of billed system restoration charges, the REP must pay the disputed amount under protest according to the timelines detailed in paragraph (d). The REP and servicer must first attempt to informally resolve the dispute, but if they fail to do so within 30 calendar days, either party may file a complaint with the Commission. If the REP is successful in the dispute process (informal or formal), the REP must be entitled to interest on the disputed amount paid to the servicer at the Commission-approved interest rate. Disputes about the date of receipt of system restoration charge payments (and penalties arising thereof) or the size of a required REP deposit will be handled in a like manner. It is expressly intended that any interest paid by the servicer on disputed amounts must not be recovered through system restoration charges if it is determined that the servicer’s claim to the funds is clearly unfounded. No interest must be paid by the servicer if it is determined that the servicer has received inaccurate metering data from another entity providing competitive metering services under PURA § 39.107.

If the servicer is providing the metering, metering data will be provided to the REP at the same time as the billing. If the servicer is not providing the metering, the entity providing the metering services will be responsible for complying with Commission rules and ensuring that the servicer and the REP receive timely and accurate metering data for the servicer to meet its obligations under the servicing agreement and this Financing Order with respect to billing and true-ups.

The REP will be allowed to hold back an allowance for charge-offs in its payments to the servicer. Such charge-off rate will be recalculated each year in connection with the annual true-up procedure. In the initial year, REPs will be allowed to remit payments based on the same charge-off percentage used by the REP to remit payments to the servicer in connection with the most recently established system restoration charges related to the system restoration bonds issued by CenterPoint Energy Restoration Bond Company, LLC on November 25, 2009. On an annual basis in connection with the true-up process, the REP and the servicer will be responsible for reconciling the amounts held back with amounts actually written off as uncollectible in accordance with the terms agreed to by the REP and the servicer, provided that:

In the event that the servicer is billing retail customers for system restoration charges, the servicer must have the right to terminate transmission and distribution service to the end-use customer for non-payment by the end-use customer under applicable Commission rules. In the event that a REP or the POLR is billing customers for system restoration charges, the REP or POLR must have the right to transfer the customer to the POLR (or to another certified REP) or to direct the servicer to terminate transmission and distribution service to the end-use customer for non-payment in accordance with the applicable Commission rules.

⁶³ Application of Centerpoint Energy Houston Electric, LLC For Authority to Change Rates, Docket No. 49421, Final Order (March 9, 2020).

Such amounts are referred to as the Periodic Payment Requirement (PPR) and the amounts necessary to be billed to collect such PPR are referred to as the Periodic Billing Requirement (PBR). With respect to any series of system restoration bonds, the servicer will make true-up adjustment filings with the Commission at least annually, within 45 days of the anniversary of the date of the original issuance of the system restoration bonds of that series.

For each Non-residential SRC Group as defined in Schedule SRC, an adjustment factor will be computed by dividing (1) the amount assigned to the group in step (a) above by (2) the sum of the existing rates times the forecasted billing determinants for each class in the group. For each class in the group, the system restoration charge for the upcoming period will be the product of the existing system restoration charge times the adjustment factor for the group in which that class resides.

The scope of the proceeding will be limited to determining whether the proposed adjustment complies with this Financing Order. In any true-up proceeding that involves the adjustment of the PBRAFs, all parties in the proceeding must have the right to challenge the reasonableness of the forecasts of billing determinants proposed as a basis for adjusting the PBRAFs. The Commission will issue a final order by the proposed adjustment date stated in the filing. In the event that the Commission cannot issue an order by that date, the servicer will be permitted to implement its proposed changes. Any modifications subsequently ordered by the Commission will be made by the servicer in the next true-up filing.

In accordance with these findings of fact and conclusions of law, the Commission issues the following orders.

Appendix A Page 1 of 16 FORM OF ISSUANCE ADVICE LETTER day, , 2025 DOCKET NO. XXXX THE PUBLIC UTILITY COMMISSION OF TEXAS SUBJECT: ISSUANCE ADVICE LETTER FOR SYSTEM RESTORATION BONDS Pursuant to the Financing Order adopted in Application of CenterPoint Energy Houston Electric, LLC for a Financing Order, Docket No. XXXX (the "Financing Order"), CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC ("Applicant") hereby submits, no later than the end of the first business day after the pricing date of this series of System Restoration Bonds, the information referenced below. This Issuance Advice Letter is for the 2025 System Restoration Bonds, tranches A- 1 thru A-_. Any capitalized terms not defined in this letter have the meanings ascribed to them in the Financing Order. PURPOSE This filing establishes the following: (a) the total amount of Qualified Costs being securitized; (b) confirmation of compliance with issuance standards; (c) the actual terms and structure of the System Restoration Bonds being issued; (d) the initial System Restoration Charge for retail users; and (e) the identification ofthe BondCo. OUALIFFED COSTS BEING SECURITIZED The total amount of Qualified Costs being securitized (the "Securitized Qualified Costs") is presented in Attachment 1.

Appendix A Page 2 of 16 COMPLIANCE WITH ISSUANCE STANDARDS The Financing Order requires Applicant to confirm, using the methodology approved therein, that the actual terms ofthe System Restoration Bonds result in compliance with the standards set forth in the Financing Order. These standards are: 1. The securitization of Qualified Costs will provide tangible and quantifiable benefits to ratepayers, greater than would be achieved absent the issuance of the System Restoration Bonds (See Attachment 2, Schedule D); 2. The amount securitized will not exceed the present value of the conventional revenue requirement over the life of the System Restoration Bonds associated with the Securitized Qualified Costs when the present value calculation is made using a discount rate equal to the proposed interest rate on the System Restoration Bonds (See Attachment 2, Schedule D); 3. The total amount of revenues to be collected under the Financing Order is less than the revenue requirement that would be recovered using conventional financing methods (See Attachment 2, Schedules C and D); 4. The System Restoration Bonds will be issued in one or more series, comprised of one or more tranches, having scheduled final payment dates of no more than 14 years from the date of issuance of such series and legal final maturities not exceeding 15 years from the date of issuance of such series (See Attachment 2, Schedule A); 5. The System Restoration Bonds may be issued with an original issue discount, additional credit enhancement, or arrangements to enhance marketability provided that the Applicant certifies that the original issue discount is reasonably expected to provide benefits greater than its cost; and 6. The structuring and pricing of the System Restoration Bonds is certified by the Applicant to result in the lowest System Restoration Charges consistent with market conditions and the terms (including the amortization structure ordered by the Commission, if any) set out in the Financing Order (See Attachment 4).

Appendix A Page 3 of 16 ACTUAL TERMS OF ISSUANCE System Restoration Bond Series: System Restoration Bond Issuer: [BondCo] Trustee: Closing Date: ,2025 Bond Ratings: Moody's Aaa, S&P AAA Amount Issued $ System Restoration Bond Up-Front Qualified Costs: See Attachment 1, Schedule B. System Restoration Bond Ongoing Qualified Costs: See Attachment 2, Schedule B. Expected Tranche Coupon Tranche Weighted Rate Size Average Life Expected Legal Final Final Payrnent Maturity A - 1 % $ yrs i l l l A - 2 % $ yrs - 12 - I l Effective Annual Weighted Average Interest Rate of the System Restoration Bonds: Life of Series: Weighted Average Life of Series: Call provisions (including premium, if any): Target Amortization Schedule: Target Final Payment Dates: Legal Final Maturity Dates: Payments to Investors: % years years Attachment 2, Schedule A Attachment 2, Schedule A Attachment 2, Schedule A Semiannually Beginning ,20 Initial annual Servicing Fee as a percent of the original System Restoration Bond principal balance: 0.10%

Appendix A Page 4 of 16 INITIAL SYSTEM RESTORATION CHARGE Table I below shows the current assumptions for each ofthe variables used in the calculation of the initial System Restoration Charges. TABLE I Input Values for Initial System Restoration Charges Applicable period: from to Forecasted retail kWh/kVA sales for the applicable Residential; kWh period: Secondary<= 10; kWh Secondary > 10; kVA Primary; kVA Lighting; kWh System Restoration Bond debt service for the applicable period: $ Percent ofbilled amounts expected to be charged-off: Forecasted % of Billing Paid in the Applicable Period: Forecasted retail kWh/kW sales billed and collected for the applicable period: Forecasted annual ongoing transaction expenses (Excluding System Restoration Bond principal and interest): $ Initial System Restoration Bond outstanding balance: $ 1.9946% % Target System Restoration Bond outstanding balance asof / / : $ Total Periodic Billing Requirement for applicable period: $ Allocation of the PBR among customer classes: See Attachment 3.

Appendix A Page 5 of 16 Based on the foregoing, the initial System Restoration Charges calculated for retail users are as follows: TABLE I[ Rate Class Initial System Restoration Charge Residential $ /kWh Secondary <= 10 kVA $ /kWh Secondary > 10 kVA $ /Per Billing kVA Primary Service $ /Per Billing kVA Lighting Services $/kWh IDENTIFICATION OF SPE The owner of the System Restoration Property will be: EFFECTIVE DATE [BondCo]. In accordance with the Financing Order, the System Restoration Charge shall be automatically effective upon the Applicant's receipt of payment in the amount of $ 1 f~om [BondCo], following Applicant's execution and delivery to [BondCo] of the Bill of Sale transferring Applicant's rights and interests under the Financing Order and other rights and interests that will become System Restoration Property upon transfer to [BondCo] as described in the Financing Order. 1 The total securitized qualified costs less the sum of up-front qualified costs and original issue discount of $

Appendix A Page 6 of 16 NOTICE Copies of this filing are being furnished to the parties on the attached service list. Notice to the public is hereby given by filing and keeping this filing open for public inspection at Applicant's corporate headquarters. AUTHORIZED OFFICER The undersigned is an officer of Applicant and authorized to deliver this Issuance Advice Letter on behalf of Applicant. Respectfully submitted, CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC By: Name: Title:

Appendix A Page 7 of 16 ATTACHMENT 1 SCHEDULE A CALCULATION OF SECURITIZED OUALIFIED COSTS Securitizable balance to be securitized $ Up-front Qualified Costs $ TOTAL SECURITIZED QUALIFIED COSTS $

Appendix A Page 8 of 16 ATTACHMENT 1 SCHEDULE B ESTIMATED UP-FRONT QUALIFIED COSTS Legal Fees (Company, Issuer, and Underwriter) $ Accountant' s Fees $ Trustee's/Trustee Counsel's Fees and Expenses $ Servicer's Set-up Costs $ Printing/Edgarizing Expenses $ Company Financial Advisor Fees & Expenses $ BondCo Setup Costs $ Company's Non-Legal Securitization Proceeding Costs & Expenses $ Company's Miscellaneous Administrative Costs $ Underwriter's Fees $ SubtotaI Capped Up-Front Qualified Costs $ $ Uncapped Up-Front Costs Commission's Financial Advisor's Fees & Expenses $ Legal Fees & Expenses for Counsel to the Commission's Advisor $ Original Issue Discount $ Cost of Other Credit Enhancements Rounding/Contingency $ Rating Agency Fees $ SEC Registration Fee TOTAL UP-FRONT QUALIFIED COSTS SECURITIZED $ Note: Certain costs are subject to an aggregate cap set forth in the Financing Order. Differences that result from the Estimated Up-front Qualified Costs securitized being more than the actual up-front costs incurred will be resolved through the true-up process described in the Financing Order. Differences that result from the Estimated Up-front Qualified Costs securitized being less than the actual up-front costs incurred may be resolved in a future proceeding as described in the Financing Order, provided that the total amount of capped costs may not be recovered in excess of the aggregate cap.

Appendix A Page 9 of 16 ATTACHMENT 2 SCHEDULE A SYSTEM RESTORATION BOND REVENUE REOUIREMENT INFORMATION SERIES ,TRANCHE Payment Date Principal Balance Interest Principal Total Payment $ $ l l ll l l 11 SERIES ,TRANCHE Payment Date Principal Balance Interest Principal Total Payment $ $ ll l l 11 11 1l l l ll 11 ll Legal Final Maturity: Tranche A-1 [DATE] Tranche A-2 [DATE]

Appendix A Page 10 of 16 ATTACHMENT 2 SCHEDULE B ONGOING QUALIFIED COSTS ANNUAL AMOUNT Ongoing Servicer Fees Fee (CenterPoint Houston as $ Servicer) (0.075% of initial System Restoration Bond principal amount) Administration Fees $ Accountants Fees $ Legal Fees/Expenses for Company's/Issuer's Counsel $ Trustee's/Trustee's Counsel Fees & Expenses $ Independent Manager's Fees $ Rating Agency Fees $ Printing/Edgarization Expenses $ Miscellaneous $ TOTAL PROJECTED ONGOING QUALIFIED $ COSTS (with CenterPoint Houston as Servicer) Ongoing Servicers Fee (Third Party as Servicer) (0.60% of $ principal amount) TOTAL PROJECTED ONGOING QUALIFIED $ COSTS (Third Party as Servicer) Note: Certain of the Ongoing Qualified Costs are subject to caps set forth in the Financing Order. The amounts shown for each category of operating expense on this attachment are the expected expenses for the first year of the System Restoration Bonds. System Restoration Charges will be adjusted at least annually to reflect any changes in Ongoing Qualified Costs through the true-up process described in the Financing Order.

Appendix A Page 11 of 16 ATTACHMENT 2 SCHEDULE C CALCULATION OF SYSTEM RESTORATION CHARGES Year Total Nominal Present Value System Restoration Ongoing System Restoration of System Bond Payments2 Qualified Costs3 Charge Restoration RequiremenP Charges5 1 $ $ $ $ 2 $ $ $ $ 3 $ $ $ $ 4 $ $ $ $ 5 $ $ $ $ 6 $ $ $ $ 7 $ $ $ $ 8 $ $ $ $ 9 $ $ $ $ 10 $ $ $ $ 11 $ $ $ $ 12 $ $ $ $ I3 $ $ $ $ 14 $ $ $ $ Total $ $ $ $ 2 From Attachment 2, Schedule A. 3 From Attachment 2, Schedule B. 4 Sum of System Restoration Bond payments and ongoing qualified costs. 5 The discount rate used is the weighted average effective annual interest rate of the System Restoration Bonds.

Appendix A Page 12 of 16 ATTACHMENT 2 SCHEDULE D COMPLIANCE WITH SUBCHAPTER G OF THE UTILITIES CODE Tangible & Quantifiable Benefits and Revenue Requirements Tests: 6 Conventional Financing Securitization Financing7 Savings/(Cost) of Securitization Financing Nominal $ million $ million $ million Present Value $ million $ million $ million 6 Calculated in accordance with the methodology cited in the Financing Order. 7 From Attachment 2, Schedule C.

Appendix A Page 13 of 16 ATTACHMENT 3 INITIAL ALLOCATION OF COSTS TO SRC CLASSES (1) (2) (3) (4) (5) (6) SRC Class Allocation Periodic Billing Forecasted SRC Charge Factorss Billing Requirement Billing Requirement per SRC Determinants Class Residential % $ $ $ /kWh Secondary <= % $ $ $ /1< 10 kVA Secondary > % $ $ $ /kWh 10 kVA Primary %$$ $ /kWh Service Lighting %$$ $ /kWh Services 100.00% $ $ $ /kWh 8 Determined in accordance with the methodology set forth in the Financing Order and Schedule SRC-2.

Appendix A Page 14 of 16 ATTACHMENT 4 FORM OF APPLICANT'S CERTIFICATION [CEHE Letterhead] Date: ,2025 Public Utility Commission of Texas 1701 N. Congress Ave. P.O. Box 13362 Austin, TX 78711-3326 [Commission's Financial Advisor] RE . Application of CenterPoint Energy Houston Electric , LLC for a Financing Order , Docket No . CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC (the "Applicant") submits this Certification pursuant to Ordering Paragraph No. _ of the Financing Order in Application of CenterPoint Energy Houston Electric , LLC Inc . for a Financing Order , Docket No . ( the "Financing Order"). All capitalized terms not defined in this letter have the meanings ascribed to them in the Financing Order. In its issuance advice letter dated , 2025, the Applicant has set forth the following particulars of the System Restoration Bonds: Name of System Restoration Bonds: SPE: [BondCo] Closing Date: Amount Issued: $ Expected Amortization Schedule: See Attachment 2, Schedule A to the Issuance Advice Letter Distributions to Investors [e.g., quarterly or semi-annually]: Weighted Average Coupon Rate: % Weighted Average Yield:9 % 9 The internal rate of return, calculated including all up-front and ongoing costs.

Appendix A Page 15 of 16 The following actions were taken in connection with the design, marketing, structuring and pricing of the bonds: • Included credit enhancement in the form of the true-up mechanism and an equity contribution of 0.50% ofthe original principal amount. • Registered the System Restoration Bonds with the U.S. Securities and Exchange Commission to facilitate greater liquidity. e Achieved preliminary Aaa/AAA ratings from two major rating agencies with final Aaa/AAA ratings as a condition of closing. • Worked with the Commission's designated representative(s) to select underwriters that have relevant experience and execution capability. ® Provided the term sheet and preliminary prospectus by e-mail to prospective investors. • Allowed sufficient time for investors to review the term sheet and preliminary prospectus and to ask questions regarding the transaction. e Arranged for the issuance ofrating agency pre-sale reports during the marketing period. ® During the period that the System Restoration Bonds were marketed, held daily market update discussions with the underwriting team to develop recommendations for pricing. e Had multiple conversations with all of the members of the underwriting team before and during the marketing phase in which we stressed the requirements of the Financing Order. • Developed and implemented a marketing plan designed to give each of the underwriters incentive to aggressively market the System Restoration Bonds to their customers and to reach out to a broad base of potential investors. • Provided potential investors with access to an internet roadshow for viewing on repeated occasions at investors' convenience. • Adapted the System Restoration Bond offering to market conditions and investor demand at the time of pricing. Variables impacting the final structure of the transaction were evaluated including the length of average lives and maturity of the System Restoration Bonds and interest rate requirements at the time of pricing so that the structure of the transaction would correspond to investor preferences and rating agency requirements for AAA ratings, while meeting the requirements of the Financing Order. [After evaluation, incorporated the use of original issue discount to investors consistent with the expectation that it would provide greater benefit than its cost]

Appendix A Page 16 of 16 • Worked with the Commission's designated representative to develop bond allocations, underwriter compensation and preliminary price guidance designed to achieve lowest interest rates. • Worked with Commission and underwriters (and each of our respective counsels) to finalize documentation in accordance with established standards for transaction ofthis sort and the terms of the financing order. [Note: foregoing bullet points are illustrative and will be modified to reflect actual activities in this transaction] Based upon information reasonably available to the officers, agent, and employees of the Applicant, the Applicant hereby certifies that the structuring and pricing of the System Restoration Bonds, as described in the issuance advice letter, will result in the lowest system restoration bond charges consistent with market conditions and the terms of the Financing Order (including the amortization structure, if any, ordered by the Commission), all within the meaning of Sections 39.302 and 36.401 ofPURA. CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC By: Name: Title:

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 1 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area 6.1.1.2.4 SCHEDULE SRC - SYSTEM RESTORATION CHARGES SECTION 1: APPLICABILITY This schedule sets out the rates and terms and conditions under which System Restoration Charges (SRC or SR Charges) will be billed and collected by CenterPoint Energy Houston Electric, LLC (Company), any successor servicer(s) and any retail electric providers (REP) or collection agents billing or collecting SR Charges on behalf of CenterPoint Energy Restoration Bond Company II, LLC (SPE). The SR Charges were authorized by the Financing Order approved by the Public Utility Commission of Texas (Commission) in Docket No. 57559 on [XXXXX] (Financing Order). Pursuant to terms of the Financing Order and the requirements of Section 36.401 et seq. of the Texas Utilities Code, all of the Company's rights under the Financing Order, including the right to bill and collect SR Charges and to adjust SR Charges pursuant to this Schedule SRC, were transferred to the SPE in connection with the issuance of system restoration bonds. The rights transferred to the SPE are "transition property" of the SPE (as defined in Section 39.304 of the Utilities Code). On the effective date of this Schedule SRC the Company will act as servicer on behalf of the SPE to bill, collect, receive and adjust SR Charges imposed pursuant to this Schedule SRC. However, the SPE may select another party to serve as servicer or the Company may resign as servicer in accordance with the terms and subject to the conditions of the Servicing Agreement and the Financing Order. A successor servicer selected under these conditions will assume the obligations of the Company as servicer under this Schedule SRC. As used in this Schedule SRC, the term "Servicer" includes any successor servicer. All actions by the Company under this Schedule SRC, including collection of SR Charges, will be undertaken solely in its role as servicer under the Servicing Agreement between the Company and the SPE dated as of [XXXXX.] This schedule is applicable to: 1. Retail customers located within the certificated service area of Company as such service area existed on [date of Financing Order] who receive electric distribution service through a REP served by the Company and to the facilities, premises and loads of such retail customers; 2. Retail customers located within Company's certificated service area as it existed on [date ofFinancing Order] who are presently receiving distribution service either directly from another utility, electric cooperative or municipally owned utility (T or D Provider) or through a REP served by another T or D Provider, and whose request to change service to the other T or D Provider was made after [date of Financing Order]; 3. Retail customers located within Company's certificated service area as it existed on [date of Financing Order] and who are served by New On-Site Generation. New Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 2 o f 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area On-Site Generation means "New On-Site Generation" as defined in the Financing Order. 4. REPs that serve retail customers located within Company's certificated service area as it existed on [date of Financing Order]. 5. Any other entity which, under the terms of the Financing Order or the Utilities Code, may be obligated to pay, bill, collect, or adjust the System Restoration Charges. SECTION 2: CHARACTER OF SYSTEM RESTORATION CHARGES SR Charges are non-bypassable charges. All SR Charges other than those applicable to New On-Site Generation are computed and paid on the basis of individual end-use retail customer consumption or demand. In accordance with the Financing Order, the SR Charges applicable to use ofNew On-Site Generation that results in a "material reduction" ofthe customer's use ofenergy delivered through the Company's distribution facilities (as defined in the Financing Order) are computed and paid based on the output of the onsite generation used to meet the internal electric requirements of the customer. Customers with New On-Site Generation will also be required to pay the SR Charges applicable to energy actually delivered to the Customer through the Company's facilities. Individual end use retail customers are responsible for paying SR Charges billed to them in accordance with the terms of this Schedule SRC whether the charges are billed directly by Servicer or are included in the bills submitted to the customer by a REP or another entity. Payment is to be made to the entity that bills the customer in accordance with the terms of the Servicing Agreement and the Financing Order. The billing entity may be the Company, a successor servicer, a REP or an entity designated to collect SR Charges in place of the REP. The SR Charges are separate charges to be paid in addition to any other applicable charges for services received. Although the SR Charges are separate charges, they may be included within other charges of the billing entity. The REP or entity designated to collect SR Charges in place of the REP will pay SR Charges (less an allowance for charge-offs calculated pursuant to this Schedule SRC) to Servicer in accordance with the requirements of the Financing Order and this Schedule SRC whether or not it has collected the SR Charges from its customers. To the extent that the REP's actual charge-offs differ from the charge-off allowance, adjustments will be made pursuant to this Schedule SRC. The REP will have no right to reimbursement other than as expressly set out in this Schedule SRC. Servicer will remit collections to the SPE in accordance with the terms ofthe Servicing Agreement. Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 3 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area SECTION 3: TERM This Schedule SRC is effective beginning on the date the system restoration bonds are issued. Schedule SRC will remain in effect as provided in the Financing Order until the SR Charges collected and remitted to the SPE are sufficient to satisfy all obligations ofthe SPE to pay principal and interest on the system restoration bonds (as due over the 14-year term of the system restoration bonds) and to pay all other qualified costs as provided in the Financing Order. However, in no event will the SR Charges be billed for service provided after 15 years from issuance of the system restoration bonds, or sooner ifthe system restoration bonds are paid in full at an earlier date. This Schedule SRC is irrevocable. SECTION 4: SYSTEM RESTORATION CHARGE CLASSES SR Charges are calculated and applied by SRC Class. There are 5 SRC Classes. Each SRC Class is defined in terms of the base rate tariff classes existing on the Company's system on [date of Financing Order]. The SRC Classes are: Residential Service Secondary Service Less Than or Equal to 10 kVA Secondary Service Greater than 10 kVA Primary Service Lighting Services SECTION 5: PERIODIC BILLING REOUIREMENT ALLOCATION FACTORS The initial Periodic Billing Requirement Allocation Factors ("PBRAF") for each SRC Class are set out below. These initial PBRAFs will remain in effect throughout the life of the system restoration bonds unless a modification of the factors is made pursuant to the allocation factor adjustment provisions in Section 6 ofthis Schedule SRC: INITIAL PERIODIC BILLING REQUIREMENT ALLOCATION FACTORS SRC PBRAF CLASS Residential Service 55.4597% Secondary Service Less Than or Equal to 10 kVA 1.5261% Secondary Service Greater than 10 kVA 31.7972% Primary Service 2.4092% Lighting Services 8.8078% Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 4 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area SECTION 6: ALLOCATION FACTOR ADJUSTMENTS The PBRAFs will be subject to adjustment using the procedures in this Section 6. Any adjustment required under this Section 6 will be made effective on the date of an annual Standard True-up Adjustment. Required adjustments will be made in the following order: first, adjustments will be made under Part A; second, adjustments will be made under Part B. For purposes of determining whether an allocation adjustment is required under Parts A and B of this Section 6 and adjusting PBRAFs pursuant to those Parts, the SRC Classes will be combined into two groups (SRC Groups) as follows: SRC GROUPS SRC GROUP SRC INITIAL GROUP CLASSES ALLOCATION PERCENTAGE Residential Residential 55.4597% Non-Residential All other SRC Classes 44.5403% Part A: Inter-Group Adjustments Due to Cumulative Load Loss In connection with each annual Standard True-up Adjustment, the Company will compare the projected billing determinants being used to set SR Charges for each SRC Class during the ensuing year to the billing determinants in effect on the original effective date of Schedule SRC (such billing determinants are hereafter referred to as the "Base Billing Determinants"). The PBRAFs ofall SRC Classes in all SRC Groups will be adjusted if one or more SRC Groups experience load loss aggregating 50% or more on a cumulative basis when measured against the Base Billing Determinants. The adjustments under this Part A will be made using the following procedures: Step 1: For each SRC Group, if CTCOLG/PBRGk Then, no PBRAF adjustment will occur 0.50 and any adjustment made in previous years under Part A shall be reversed For each SRC Group, if CTCOLG / PBRo < Then, a PBRAF adjustment will be 0.50 calculated pursuant to Steps 2 through 5. Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 5 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area Where: CTCOLG - cumulative test collections for group G=Z CCc* FBUc for all classes (c) in Group (G) FBUc = forecasted billing determinants for class c CCc= cumulative test charge for class c = {PBRAFc*PB]4}/ BBDc PBRAFc= the PBRAFs then in effect PBRT= total periodic billing requirement for upcoming period BBDc= Base Billing Determinants for class c PBRe= periodic billing requirement for group = E PBRAFc* PBRr for all classes in G Step 2: For each SRC Group in Step 1 where CTCOLG / PBRG < 0.50, a reduction amount (REDG) Will be calculated for group G where REDG= 0.5 (PBRG - CTCOLG) Step 3: For all SRC Groups, a reallocation amount for that group (RAG) shall be calculated where: RAG = GAPo * {E REDo} for all Groups Where: GAPG = Group Allocation Percentage = I PBRAFc for all classes in the group Step 4: For all SRC groups a Group Allocation Percentage Adjustment (GAPAG) shall be calculated where: GAPAG= (RAG-REDG) / PBRT Where: EGAPAG= 0 forall G Step 5: For all SRC classes, the PBRAF adjustment for class c (PBRAFAc) will be calculated for use in calculating adjustments to the SR Charges under Section 8 where PBRAFAc=-GAPAG * (PBRAFJGAPe) Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 6 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area Part B: Inter-Group Adjustments Due to Year-Over-Year Load Loss In connection with each annual Standard True-up Adjustment, the Company will compare the projected billing determinants being usedto set SR Charges for each SRC Class during the ensuing year to the forecasted billing determinants used to develop the then currently effective SR Charges for the class (such amount is hereinafter referred to as the "Prior Year Billing Determinants"). The PBRAFs ofall SRC Classes in all SRC Groups will be adjusted if (i) one or more SRC Groups experience load loss of 10% or greater on a year-over-year basis when compared to the Prior Year Billing Determinants or (ii) any SRC Group for which an adjustment was made under this Part B in one or more prior years experiences load growth resulting in projected billing determinants for the current year at a level which, if they had existed in one or more o f such prior year(s) would have resulted in no adjustment to PBRAFs in such prior year(s). No reduction in PBRAFs will be made under this Part B for any SRC Group for which a reduction amount was computed under Step 5 of Part A. The adjustments under this Part B will be made using the following procedures: Step 1: For each SRC Group not adjusted under Part A, If YTCOLG / PBRok 0.90 Then, no PBRAF adjustment will occur. If YTCOLG/PBRG> 1.00 If YTCOLG / PBRG< 0.90 Then, no PBRAF adjustment will occur and any prior year adjustments made under B will be reversed pursuant to step 6. Then, a PBRAF adjustment will be calculated pursuant to Steps 2 through 5. Where: YTCOLo = year-to-year test collections for group G=E YCc* FBUc for all classes (c) in Group (G) FBUc = forecasted billing determinants for class c YCc= year-to-year test charge for class c = {PBRAFc*PBRr}/ FBUc-1 PBRAFc= the PBRAFs then in effect PBRr= total periodic billing requirement for upcoming period FBUc-1=prior year's forecasted billing determinants for class c PBRG= periodic billing requirement for group = E PBRAFc* PBRT for all classes in the group Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 7 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area Step 2: For each SRC Group in Step 1 where YTCOL0/ PBRG< 0.90, a year to year reduction amount (YREDG) shall be calculated where YREDG= 0.9 (PBRc; - YTCOLG) Step 3: For all SRC Groups, a year to year reallocation amount (YRAG) shall be calculated where: YRAG= GAPG * {Y YREDG} for all groups Where: GAPG = Group Allocation Percentage = E PBRAFc for all classes in the group Step 4: For all SRC groups a year to year group allocation percentage adjustment (YGAPAG) shall be calculated where: YGAPAG== (YRAG-YREDG) / PBRr Where E GAPA~ = 0 for all G Step 5: For all SRC classes, a year to year PBRAF adjustment (YPBRAFAc) shall be calculated for use in calculating adjustments to the SR Charges under Section 8 where: YPBRAFAc= YGAPAo*(PBRAFJGAPe) Step 6: if{E (YCc*FBUc)}/{E (YCc*FBU~-1)}k .90 (for all classes in group G) then the adjustment made in year t shall be discontinued. if{I (YCc*FBUc)}/{E (YCc*FBUJ-1)} < .90 (for all classes in group G) then the adjustment made in year t canies forward. Where FBUJ-1 is the forecasted billing determinants from the year prior to the year an adjustment was made. Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 8 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area SECTION 7: SYSTEM RESTORATION CHARGES The SR Charges to be applied beginning on the effective date of this Schedule SRC are set out below. SR Charges to be applied in subsequent periods (Adjusted SR Charges) will be determined in the manner described in Section 8. SYSTEM RESTORATION CHARGES SRC PER UNIT BILLING CLASS CHARGE UNIT Residential Service $0.000910 Per kWh Secondary Service Less Than $0.000902 or Equal to 10 kVA Per kWh Secondary Service Greater than 10 kVA $0.159426 Per Billing kVA Primary Service $0.0922I3 Per Billing kVA Lighting Services $0.021448 Per kWh The billing units are defined as in the base rate tariff. Any change in determination ofthese billing units will be effective for this Schedule SRC at the next annual true-up adjustment. In addition, each customer which has New On-Site Generation shall pay an amount each month computed by multiplying the output of the on-site generation used to serve the internal electric requirements of the customer (Billing kVA) by the SR Charge in effect for services provided to customers in that class during the month. This amount shall be in addition to any SR Charges applicable to demand actually delivered to the customer through the Company's or another T&D Provider's facilities. SECTION 8: STANDARD TRUE-UP FOR ADJUSTMENT OF SR CHARGES SR Charges will be adjusted annually effective on [October 15th] to ensure that the expected collection of SR Charges is adequate to pay principal and interest on the system restoration bonds when due pursuant to the expected amortization schedule, and pay as due all other qualified costs. In addition to annual true-up adjustments, true-up adjustments may be made by the servicer more frequently at any time during the term of the system restoration bonds to correct any forecasted undercollection of system restoration charges in order to assure timely payment of the system restoration bonds, including the replenishment of any funds drawn from the capital subaccount. All annual and interim adjustments will be designed to cause (i) the outstanding principal balance of the system restoration bonds to be equal to the scheduled balance on the expected amortization schedule; (ii) the amount in the capital subaccount to be equal to the required capital plus any Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 9 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area investment earnings on amounts in the capital subaccount to the extent that the investment earnings have not been released to the SPE. TRUE-UP ADJUSTMENT PROCEDURE FOR STANDARD AND INTERIM TRUE-UPS Servicer will calculate the Adjusted SR Charges using the methodology described below and will file the Adjusted SR Charges with the Commission. Annual adjustments will be filed 15 days prior to the effective date of the Adjusted SR Charges unless an adjustment to the PBRAFs is required under Section 6 in which case the annual adjustment will be filed not later than 90 days prior to the effective date. Interim Adjustments will be filed not less than 15 days prior to the effective date of the Adjusted SR Charges. The Adjusted SR Charge for the upcoming period for each class (SRCc) shall be computed as follows: Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 10 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area For the residential class, SRCc= PBRT*(PBRAFc+PBRAFAc+YPBRAFAct)/FBUc For classes in the Non-Residential SRC Group: SR.Cc= SRCc-1 {F [PBR.r * (PBRAFc+PBRAFAc-I-YPBRAFAO] / E(SRCc-1*FBUc)} For all classes in the non-residential group, Where SRCc-1 = the SR charge for that class from the previous period PBRT = Periodic Billing Requirement for the ensuing period (the 12 months beginning on the effective date of the adjusted SR Charges in the case of annual true-ups and the period until the next scheduled annual true-up in the case of interim adjustments). The Periodic Billing Requirement will be the amounts required to pay principal and interest on the system restoration bonds when due pursuant to the expected amortization schedule, pay as due all other qualified costs, and recover any net system under-collections or credit any net system over-collections so that (i) the outstanding principal balance of the system restoration bonds will be equal to the scheduled balance on the expected amortization schedule; (ii) the amount in the capital subaccount will be equal to the required capital plus any investment earnings on amounts in the capital subaccount to the extent that the investment earnings have not been released to the SPE. PBRAFc = the PBRAFs then in effect. PBRAFAc= the adjustment (if any) from Section 6, Part A, Step 5 YPBRAFAct= the adjustment from Section 6, Part B, Step 5 for every year t in which an adjustment was made unless that adjustment was discontinued under Section 6, Part B, Step 6. FBUc= the forecasted billing determinants for the upcoming period Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 11 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area SECTION 9: BILLING AND COLLECTION TERMS AND CONDITIONS SR Charges will be billed and collected as set forth in this Schedule SRC. The terms and conditions for each party are set forth below. A. Billings by Servicer to other T or D Providers: 1. SR Charges applicable to former retail customers of the Company in multiply certificated service areas who are now taking service directly from other T or D Providers or through REPs served by other T or D Providers will be billed to and collected from the other T or D Provider, which, in turn will be responsible for collecting the SR Charges from the retail customers and REPs. 2. The T or D Provider shall pay all SR Charges not later than 35 days after bill is mailed by Servicer. The T or D Provider shall make such payment regardless of whether it collects such charges from the end-use retail customer or REP. B. Billings by Servicer to New On-Site Generation: 1. Customers subject to SR Charges for New On-Site Generation shall pay such charges in full not later than sixteen days after the date the bill is mailed to the customer. 2. SR Charges applicable to New On-Site Generation are in addition to applicable SR Charges under A above or C below. 3. If the entity with New On-Site Generation receives transmission or distribution service from the Company or another T or D Provider, Servicer shall have the same right to terminate service or require the other provider to terminate service for non-payment of SR Charges as the Company has to terminate service for non-payment of charges under the Company's rate schedules. Any termination shall comply with applicable Commission rules. C. Billings by the REP or its replacement to end-use customers: 1. REPs will bill and collect, or cause to be billed and collected, all SR Charges applicable to consumption by retail customers served by the REP. 2. If Servicer is providing the metering, metering data will be provided to the REP at the same time as the billing. If Servicer is not providing the metering, the entity providing metering services will be responsible for complying with Commission rules and ensuring that Servicer and the REP will receive timely and accurate Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 12 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area metering data in order for Servicer to meet its obligations under the Servicing Agreement and the Financing Order with respect to billing and true-ups. 3. Each REP must (1) have a long-term, unsecured credit rating ofnot less than "BBB- " and "Baa3" (or the equivalent) from Standard & Poor's and Moody's Investors Service, respectively, or (2) provide to the indenture trustee (a) a deposit of two months' maximum expected system restoration charge collections in the form of cash, (b) an affiliate guarantee, surety bond, or letter of credit providing for payment of such amount o f system restoration charge collections in the event that the REP defaults in its payment obligations, or (c) a combination of any of the foregoing. A REP that does not have or maintain the requisite long-term, unsecured credit rating may select which alternate form of deposit, credit support, or combination thereof it will utilize, in its sole discretion. The indenture trustee must be a beneficiary of any affiliate guarantee, surety bond or letter of credit. The provider of any affiliate guarantee, surety bond, or letter of credit must have and maintain a long-term, unsecured credit rating of not less than "BBB-" and "Baa3" (or the equivalent) from Standard & Poor's and Moody's Investors Service, respectively. 4. If the long-term, unsecured credit rating from either Standard & Poor's or Moody's Investors Service of a REP that did not previously provide the alternate form of deposit, credit support, or combination thereof or of any provider of an affiliate guarantee, surety bond, or letter of credit is suspended, withdrawn, or downgraded below"BBB-" or "Baa3" (or the equivalent), the REP must provide the alternate form of deposit, credit support, or combination thereof, or new forms thereof, in each case from providers with the requisite ratings, within 10 business days following such suspension, withdrawal, or downgrade. A REP failing to make such provision must comply with the provisions set forth in paragraph 3 of Section D, Billings by Servicer to the REP or its replacement (when applicable). 5. The computation of the size of a required deposit shall be agreed upon by Servicer and the REP, and reviewed no more frequently than quarterly to ensure that the deposit accurately reflects two months' maximum collections. Within 10 business days following such review, (1) the REP shall remit to the indenture trustee the amount of any shortfall in such required deposit or (2) Servicer shall instruct the indenture trustee to remit to the REP any amount in excess of such required deposit. A REP failing to so remit any such shortfall must comply with the provisions set forth in Paragraph 3 of the Section D, Billings by Servicer to the REP or its replacement (when applicable). REP cash deposits shall be held by the indenture trustee, maintained in a segregated account, and invested in short-term high quality investments, as permitted by the rating agencies rating the system restoration bonds. Investment earnings on REP cash deposits shall be considered part of such cash deposits so long as they remain on deposit with the indenture trustee. At the Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 13 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area instruction of Servicer, cash deposits will be remitted with investment earnings to the REP at the end of the term of the system restoration bonds unless otherwise utilized for the payment of the REP's obligations for System Restoration Bond payments. Once the deposit is no longer required, Servicer shall promptly (but not later than 30 calendar days) instruct the indenture trustee to remit the amounts in the segregated accounts to the REP. 6. In the event that a REP or the Provider of Last Resort (POLR) is billing customers for SR Charges, the REP shall have the right to transfer the customers to the POLR (or to another certified REP) or to direct Servicer to terminate transmission and distribution service to the end-use customer for non-payment by the end-use customer pursuant to applicable Commission rules. D. Billings by Servicer to the REP or its replacement (when applicable): 1. Servicer will bill and collect from REPs all SR Charges applicable to consumption by retail customers served by the REP, including applicable customers served by New On-Site Generation. 2. Payments of SR Charges are due 35 calendar days following each billing by Servicer to the REP, without regard to whether or when the REP receives payment from the end-use retail customers. Servicer shall accept payment by electronic funds transfer, wire transfer, and/or check. Payment will be considered received the date the electronic funds transfer or wire transfer is received by Servicer, or the date the check clears. A 5% penalty is to be charged on amounts received after 35 calendar daysi however, a 10 calendar-day grace period will be allowed before the REP is considered to be in default. A REP in default must comply with the provisions set forth in paragraph 3 of this Section D. The 5% penalty will be a one-time assessment measured against the current amount overdue from the REP to Servicer. The "current amount" consists of the total unpaid SR Charges existing on the 36th calendar day after billing by Servicer. Any and all such penalty payments will be made to the indenture trustee to be applied against SR Charge obligations. A REP shall not be obligated to pay the overdue SR Charges of another REP. If a REP agrees to assume the responsibility for the payment of overdue SR Charges as a condition of receiving the customers of another REP that has decided to terminate service to those customers for any reason, the new REP shall not be assessed the 5% penalty upon such SR Charges; however, the prior REP shall not be relieved of the previously-assessed penalties. 3. After the 10 calendar-day grace period (the 45th calendar day after the billing date), Servicer shall have the option to seek recourse against any cash deposit, affiliate guarantee, surety bond, letter of credit, or combination thereof provided by the REP, and avail itself of such legal remedies as may be appropriate to collect any Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 14 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area remaining unpaid SR Charges and associated penalties due Servicer after the application ofthe REP's deposit or alternate form of credit support. In addition, a REP that is in default with respect to the requirements set forth in paragraphs 4 and 5 of Section C and paragraph 2 of this Section D shall select and implement one of the following options: (a) Allow the POLR or a qualified REP of the customer's choosing to immediately assume the responsibility for the billing and collection of SR Charges. (b) Immediately implement other mutually suitable and agreeable arrangements with Servicer. It is expressly understood that Servicer's ability to agree to any other arrangements will be limited by the terms ofthe Servicing Agreement and requirements of rating agencies that have rated the system restoration bonds necessary to avoid suspension, withdrawal or downgrade of the ratings on the system restoration bonds. (c) Arrange that all amounts owed by retail customers for services rendered be timely billed and immediately paid directly into a lock-box controlled by Servicer with such amounts to be applied first to pay SR Charges before the remaining amounts are released to the REP. All costs associated with this mechanism will be borne solely by the REP. If a REP that is in default does not immediately select and implement one of the options specified in (a), (b) or (c) or, after so selecting one ofthe foregoing options, fails to adequately meet its responsibilities thereunder, then Servicer shall immediately implement option (a), subject to the limitations and requirements of the bankruptcy code if the REP is a debtor in bankruptcy. Upon re-establishment of compliance with the requirements set forth in paragraphs 4 and 5 of Section C and paragraph 2 of this Section D and the payment of all past-due amounts and associated penalties, the REP will no longer be required to comply with this paragraph 3. 4. The POLR appointed by the Commission must meet the minimum credit rating or deposit/credit support requirements described in paragraph 3 of Section C ("Billings by the REP or its Replacement to end-use customers") in addition to any other standards that may be adopted by the Commission. If the POLR defaults or is not eligible to provide such services, responsibility for billing and collection of SR Charges will immediately be transferred to and assumed by Servicer until a new POLR can be named by the Commission or the customer requests the services of a certified REP. Retail customers may never be re-billed by the successor REP, the POLR, or Servicer for any amount of SR Charges they have paid their REP (although future SR Charges shall reflect REP and other system-Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 15 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area wide charge-offs). Additionally, if the amount ofthe penalty detailed in paragraph 2 of this Section D is the sole remaining past-due amount after the 45th calendar day, the REP shall not be requiredto comply with clauses (a), (b) or (c) ofparagraph 3 of this Section D, unless the penalty is not paid within an additional 30 calendar days. 5. In the event that Servicer is billing customers for SR Charges, Servicer shall have the right to terminate transmission and distribution service to the end-use customer for non-payment by the end use customer pursuant to applicable Commission rules. 6. The REP will be allowed to hold back an allowance for charge-offs in its payments to Servicer. Such charge-off rate will be recalculated each year in connection with the annual true-up procedure. In the initial year, REPs will be allowed to remit payments based on a charge-offpercentage of 1.9946%. The charge offpercentage experienced in the last full year of the SRC established in Docket No. 37200. On an annual basis in connection with the true-up adjustment process, the REP and Servicer will be responsible for reconciling the amounts held back with amounts actually written off as uncollectible in accordance with the terms agreed to by the REP and Servicer, provided that: (a) The REP's right to reconciliation for write-offs will be limited to customers whose service has been permanently terminated and whose entire accounts (Le., all amounts due the REP for its own account as well as the portion representing SR Charges) have been written off. (b) The REP's recourse will be limited to a credit against future SR Charge payments unless the REP and Servicer agree to alternative arrangements, but in no event will the REP have recourse to the indenture trustee, the SPE or the SPE's funds for such payments. (c) The REP shall provide information on a timely basis to Servicer so that Servicer can include the REP' s default experience and any subsequent credits into its calculation of the adjusted SR Charge rates for the next SR charge billing period and the REP's rights to credits will not take effect until such adjusted SR Charge rates have been implemented. 7. In the event that a REP disputes any amount of billed SR Charges, the REP shall pay the disputed amount under protest according to the timelines detailed in paragraph 2 of this Section D. The REP and Servicer shall first attempt to informally resolve the dispute, but if they fail to do so within 30 calendar days, either party may file a complaint with the Commission. If the REP is successful in the dispute process (informal or formal), the REP shall be entitled to interest on the disputed amount paid to Servicer at the Commission-approved interest rate. Revision Number: Effective: XXXXXX

Appendix B Chapter 6: Company Specific Items Sheet No. 6.7.4 Page 16 of 16 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area Disputes about the date of receipt of SR Charge payments (and penalties arising thereof) or the size of a required REP deposit will be handled in a like manner. It is expressly intended that any interest paid by Servicer on disputed amounts shall not be recovered through SR Charges if it is determined that Servicer's claim to the funds is clearly unfounded. No interest shall be paid by Servicer if it is determined that Servicer has received inaccurate metering data from another entity providing competitive metering services pursuant to Utilities Code Section 39.107. 8. If Servicer is providing the metering, metering data will be provided to the REP at the same time as the billing. If Servicer is not providing the metering, the entity providing metering services will be responsible for complying with Commission rules and ensuring that Servicer and the REP will receive timely and accurate metering data in order for Servicer to meet its obligations under the Servicing Agreement and the Financing Order with respect to billing and true-ups. OTHER TERMS AND CONDITIONS If the customer or REP pays only a portion of its bill, a pro-rata portion of SR Charge revenues shall be deemed to be collected. The Company will allocate any shortfall first, ratably based on the amount owed for SR Charges and the amount owed for other fees and charges, other than late charges, owed to the Company or any successor, and second, all late charges shall be allocated to the Company or any successor. If the Company does not regularly include the notice described below in the bills sent by it to REPs or directly to retail customers, then at least once each year the Company shall cause to be prepared and delivered to REPs and such customers a notice stating, in effect, that the amount billed includes SR Charges which were authorized by the Financing Order dated [XXXXX] and have been transferred to and are being collected on behalfofCenterPoint Energy Restoration Bond Company II, LLC [BondCo] and are not owned by the Company. In the customer's initial bill from the REP and at least once each year thereafter, each REP that bills SR Charges shall cause to be prepared and delivered to its customers a notice stating, in effect, that the amount billed includes SR Charges which were authorized by the Financing Order dated [XXXXX]and have been transferred to and are being collected on behalf of CenterPoint Energy Restoration Bond Company II, LLC [BondCo] and are not owned by the REP or the Company, and that under certain circumstances described in Schedule SRC Servicer may be permitted to collect the SR Charges directly from the retail customer. Such notice shall be included either as an insert to or in the text of the bills delivered to such REPs or customers, as applicable, or shall be delivered to REPs or customers by electronic means or such other means as Servicer or the REP may from time to time use to communicate with their respective customers. Revision Number: Effective: XXXXXX

Appendix C Schedule 5_Qualified Costs Page 1 of 1 CenterPoint Energy Houston Electric, LLC Projected Qualified Costs [A] [8] [C] [D] [E] [F] [G] On-Going Costs On-Going Costs ContorPoint Houston as Sorvicer Expected Case Sensitivity Case NPV PV @ PV @ Description of Cost items Upfront Costs Year Annual Amount Period 4.90% 7.24% Legal Fees/Exp for Company's/Undorwritofs Counsel 1 $ 2,375,000 [1] 2025 $ 350,821 0.6 $ 340,894 $ 336,412 Fee for Commission's Financial Advisor $ 50,000 [1] 2026 $ 701,641 1.6 $ 649,941 $ 627,399 Fee for Company's Financial Advisor $ 300,000 [1] 2027 $ 701,641 2.6 $ 619,582 $ 585,042 Printing/Edgarizjng Expenses $ #0,®0 [1] 2028 $ 701,641 3.6 $ ' 590,640 $ 545,545 Securitization Proceeding Expenses $ 2029 $ 701,641 4.6 $ 563,051 $ 508,714 Miscellaneous Administrative Costs $ 11,294 [1] 2030 $ 701,641 5.6 $ 536,750 $ 474,370 Accountant's Fees $ 185,000 [1] 2031 $ 701,641 6.6 $ 511,678 $ 442,344 Servicer Set-up Costs $ - [1] 2032 $ 701,641 7.6 $ 487,777 $ 412,480 Trustee's/Trustee's Counsel Foos and Expenses $ 25,000 [1] 2033 $ 701,641 8.6 $ 464,992 $ 3&4,633 2034 $ 701,641 9.6 $ 443,272 $ 358,666 2035 $ 701,641 10.6 $ 422,566 $ 334,451 2036 $ 701,641 11.6 $ 402,828 $ 311,872 Total Fixed Qualified Costs* $ 2.9?6,294 2037 $ 701,641 12.6 $ 384,011 $ 290,817 *Subject to proposed cap on upfront costs 2038 $ 701,641 13.6 $ 366,074 $ 271,183 2039 $ 350,821 14.6 $ 174,487 $ 126,437 Total $ 9,822,974 Total $ 6,958,544 $ 6,010,364 OC Acct $ - $ - $ 6,958,544 $ 6,010,364 Item A Net Socuritized Amount Before Qualified Costs $ 396,325,134 Item B Fixed qualified Costs $ 2,996,294 Net Securitized Amount Including Fixed Costs (Items A+B) $ 399,321,428 Other Qualified Costs &]mlnL B@!2 Item C Undonwritofs Spread (%) $ 1,606,084 [2] 0.400% Item D SEC Fees (%) $ 61,473 0.015% Rating Agoncy Fees: Item E Moody's (Min of $255,000) $ 301,141 [3] 0.075% Item F S&P (Min of $200,000 / Max of $650,000) $ 230,875 [3] 0.058% Total Other Qualified Costs $ 2,199,572 Total AJI Qualified Costs (Fixed & Other) $ 5,195,866 Net Securitzed Amount Including All Qualified Costs $ 401,521,000 Itemized Ongoing Costs Description Annual Semi-Annual Ongoing Sorvic:or Foo (Third Party as Servicer) (0.60% of principal amount) $ 2,409,126 $ 1,204,563 [Ongoing Sorvicer Foo. (CEHEE gj Se~xic~).(0·076©# p®*#kmo®i) _ $ , 301,141 $ 150,571 Administration Fee $ 100,000 [1] $ 50,000 Accountants' Fees $ 170,000 [1] $ 85,000 Logal Fees/Expenses for Company's/lssuefs Counsel $ 25,000 [1] $ 12.500 Trustee's/Trustee's Counsel Fees and Expenses $ 5,000 [1] $ 2,500 Independent Managers' Foo $ 3,500 [1] $ 1,750 Rating Agency Fees $ 77,000 (1] $ 38,500 Pfinting/EDGARization Expenses $ 10,000 [1] $ 5,000 Miscellaneous $ 10.000 [1] $ 5,000 TOTAL (CEHE as Sonicer) $ 701,641 $ 350,821 TOTAL (Third Party as Sorvicer) $ 2,809,626 $ 1,404,813 Notes: [1] Estimates based on precedent transactions, updated to current conditions [21 $4.00 per bond (for the 2008 System Restoration Bonds, the underwriting spread was $4.25 per bond) r31 Estimates based on latest information obtainod from rating agencies

Appendix D Chapter 6: Company Specific Items Sheet No. 6.14.7 Page 1 of 2 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area 6.1.1.6.10 RIDER AI*ITC - ADFIT CREDIT APPLICABILITY Pursuant to the Financing Order in Public Utility Commission of Texas Docket No. 57559, the ADFIT Credit ("ADFITC") is a negative charge to customers subject to Schedule SRC to provide customers the accumulated deferred federal income tax (ADFIT) benefits associated with the May 2024 EOP Storm restoration costs. This schedule is applicable to distribution voltage level Retail customers and any other entity obligated to pay charges as defined under Schedule SRC. TERM This Rider ADFITC is effective beginning on the date Schedule SRC is effective and will remain in effect over the 14-year term of Schedule SRC. ADFITC ALLOCATFON FACTORS The ADFITC Allocation Factors are the same as the PBRAFs in Schedule SRC and shall be adjusted to coincide with any PBRAF adjustments for Schedule SRC. The ADFITC Charges to be applied beginning on the effective date of this Rider ADFITC are set out below. ADFITC Charges to be applied in subsequent periods will be determined in the annual true-up process described below. ADFIT CREDIT CHARGES ADFITC PER UNIT BILLING CLASS CHARGE UNIT Residential Service ($0.000187) Per kWh Secondary Service Less Than or Equal to 10 kVA ($0.000185) Per kWh Secondary Service Greater than 10 kVA ($0.032687) Per Billing kVA Primary Service ($0.018907) Per Billing kVA Lighting Services ($0.004397) Per kWh Revision Number: 14th Effective: XXXXXX

Appendix D Chapter 6: Company Specific Items Sheet No. 6.14.7 Page 2 of 2 CenterPoint Energy Houston Electric, LLC Applicable: Entire Service Area The ADFITC classes and billing units are defined the same as the classes and billing units in Schedule SRC. In addition, ADFITC Charges are applicable to each customer which has New On-Site Generation as defined in Schedule SRC as and to the extent Schedule SRC charges are applicable to such customers. ANNUAL TRUE-UP FOR ADJUSTMENT OF ADFITC CHARGES ADFITC Charges shall be adjusted at least annually effective on each date that charges in Schedule SRC become effective. The adjustment shall be made through a separate filing submitted at the same time as the Schedule SRC system restoration charge adjustment filing and using the same allocation factors and billing determinants as the system restoration charge adjustment filing. The ADFITC Charges shall be adjusted to (1) correct any over-credit or under-credit of the amounts previously scheduled to be provided to customers, (2) reflect the amounts scheduled to be provided to customers during the period the adjusted ADFITC Charges are to be effective, and (3) account for the effects, if any, on ADFIT of any insurance proceeds, government grants or other source of funding that compensate CenterPoint Houston for system restoration costs incurred. TRUE-UP ADJUSTMENT PROCEDURE FOR ANNUAL TRUE-UPS Adjusted ADFITC Charges shall be calculated using the same methodology as described in Schedule SRC for the system restoration charges. The ADFITC Groups are defined the same as Schedule SRC Groups. Annual adjustments will be filed 15 days prior to the effective date ofthe Adjusted ADFITC Charges unless an adjustment to the ADFITC Allocation Factors is required in which case the annual adjustment will be filed not later than 90 days prior to the effective date. OTHER TERMS AND CONDITIONS Ifthe customer or REP pays only a portion of its bill, a pro-rata portion ofADFITC Charge credits shall be deemed to be credited equal to the pro-ram portion of Schedule SRC deemed collected according to Schedule SRC. NOTICE This Rate Schedule is subject to the Company's Tariff and Applicable Legal Authorities. Revision Number: 14th Effective: XXXXXX

APPLICATION OF CENTERPOINT	§	PUBLIC UTILITY COMMISSION
ENERGY HOUSTON ELECTRIC, LLC	§
FOR A FINANCING ORDER FOR	§	OF TEXAS
SYSTEM RESTORATION COSTS	§
ASSOCIATED WITH MAY 2024	§
EMERGENCY OPERATIONS PLAN	§
STORMS	§

	PUBLIC UTILITY COMMISSION OF TEXAS

	/s/ Thomas J. Gleeson
	THOMAS J. GLEESON, CHAIRMAN

	/s/ Kathleen Jackson
	KATHLEEN JACKSON, COMMISSIONER

	/s/ Courtney K. Hjaltman
	COURTNEY K. HJALTMAN, COMMISSIONER