HOW TO BE AN INTERVENOR FOR LANDOWNERS

DISCLAIMER: This is NOT meant to be all-inclusive list of how-to’s. This is NOT meant to be

a substitute for securing legal services from an attorney or consultant. But it is an attempt

to help EVERYONE begin to understand the process, and to share with others. All our

information plus much more that we cannot reproduce efficiently comes from the websites

of ERCOT, PUC, LCRA, ONCORE and CPE-Energy. This is only intended to help citizens

move forward in their search for information.

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Motion to Intervene - This is the written request someone must file to become an

intervenor. In this motion, they must explain why they have a legal interest in the

proceedings. Intervenors are people directly affected by a particular issue or action and

are full and active participants in a proceeding at the PUC. Landowners are directly

aƯected. Intervenors can make legal arguments, conduct discovery, file testimony, and

cross-examine witnesses. If you file testimony, you may be cross-examined by the other

parties or their attorneys in the case.

The Public Utility Commission of Texas (PUC or PUCT) does not have a single universal

"Direct Testimony Form" because testimony formats depend on the type of case (such as

transmission line routing, rate cases, or rulemaking). However, direct testimony generally

follows a standard structure which is laid out below.

A. Sample Outline of Intervenor Direct Testimony:

1. Heading & Identification

• PUC Docket Number (This is the Docket Number assigned to the section of

the Transmission Line impacting your property. These are assigned when the

letters are sent to Landowners.)

• Style of Case (e.g., "Application of [Insert Transmission Company Name]

Electric Delivery Company LLC for a Certificate of Convenience and

Necessity for the Transmission Line”)

• Party Name (Intervenor)

• Witness Name

2. Statement of Qualifications

• Name, occupation, and relevant experience.

• Connection to the affected area (landowner, resident, business, etc.).

3. Purpose of Testimony

• Why you are providing testimony (e.g., impacts on property, environment,

reliability, cost, etc.).

4. Description of affected Property or Interest

• How the proposed project directly affects you.

• Attach maps and property descriptions as needed.

5. Impacts & Concerns

• Environmental, economic, safety, or reliability concerns. Include research

and evidence.

• Alternatives or route suggestions (if applicable).

6. Conclusion & Recommendation

• A clear statement of what you are asking the PUC to do.

7. Signature & Notarization (if required)

B. Intervenor Statement of Position – This simpler than Direct Testimony. It does not

require expert credentials or detailed legal arguments - just a clear explanation of

your position.

1. PUC Docket No.:

2. Style of Case: Application of [Insert Transmission Company Name] for a Certificate

of Convenience and Necessity

3. Intervenor Name: Full name or organization

4. Mailing Address:

5. Phone Number:

6. Email Address:

7. Statement of Position - I oppose (or support) the proposed transmission line route

as filed by because:

• Describe how the route affects your property, home, farm, ranch, business, or

environmental features. Describe how the route aƯects your property, home,

farm, ranch, business, or environmental features. Describe how the route aƯects

your property, home, farm, ranch, business, or environmental features.

• List any safety, environmental, property value, or routing concerns. List any

safety, environmental, property value, or routing concerns. List any safety,

environmental, property value, or routing concerns.

• If applicable, state your preferred route or modifications. If applicable, state your

preferred route or modifications. If applicable, state your preferred route or

modifications.

8. Closing Salutation: I respectfully request that the Public Utility Commission of

Texas consider my concerns when making its routing decision.

9. Signature: ___________________________

10. Date: ________________________________

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Next, as a cover to one of these two methods to request the opportunity to formally

intervene in a proceeding before the Public Utility Commission of Texas (PUCT), you will

need to complete and attach the official “Request to Intervene in PUC Docket No.” form.

Access the form on the PUC website, fill it out and attach it to the front of your Direct

testimony or your Statement of Position.

How to Access the Form

The official PDF form titled “Request to Intervene in PUC Docket No.” is available on the

PUCT Interchange site. https://ftp.puc.texas.gov/public/puctinfo/industry/electric/forms/ccn/Intervene.pdf

You'll need to provide information such as:

• Your identity

• Your interest or stake in the proceeding

• Acknowledgment that, as an intervenor, you'll participate fully (e.g., respond to

discovery, file testimony)

Filing Instructions

Once your official PDF form is ready, and you have completed either an Intervenor Direct

Testimony, or Intervenor Statement of Position described above you are ready to file:

• Submit digitally via the PUCT’s Interchange Filer (online system) at

https://interchange.puc.texas.gov/filer , OR

• Mail: Send the completed form along with 10 copies to PUCT Central Records:

Public Utility Commission of Texas

Attn: Filing Clerk, P.O. Box 13326, Austin, TX 78711 - 3326

• See this link for more info.

https://www.puc.texas.gov/agency/rulesnlaws/participate/

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Quick Checklist

• Complete the official Request to Intervene in PUC Docket No. PDF

• Have your Intervenor Direct Testimony OR Intervenor Statement of Position

described above ready for upload,

• Use the Interchange Filer as noted in hyperlink above or mail hard copies (plus 10)

to the address listed above.

What to Know About Being an Intervenor

• You'll be a full party to the docket, meaning you must respond to discovery, file

testimony if needed, and attend hearings.

• No attorney is required if you wish to appear as a pro se intervenor—but most

participants who represent organizations or groups choose to engage counsel.

• The deadline to intervene will typically be stated in your notice of the proceeding

should you receive one. Otherwise, please constantly check the PUC website for

information regarding deadlines. It is coming quickly. Get prepared now.

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