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CORRESP
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 CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC
 1111 Louisiana Street

 Houston,
Texas 77002

 August 13, 2025

 Via EDGAR and Electronic Mail

 United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Division of Corporation Finance
Office of Structured Finance
Attention: Komul Chaudhry and Kayla Roberts

 RE: CenterPoint Energy Restoration Bond Company II, LLC

 CenterPoint   Energy
Houston Electric, LLC
Registration Statement on Form SF-1
Filed June 20, 2025
File Nos. 333-288206 and 333-288206-01

 Ladies and Gentlemen:

 On behalf of CenterPoint Energy
Houston Electric, LLC (" CenterPoint Houston ") and CenterPoint Energy Restoration Bond Company II, LLC (the " Issuing
Entity " and, together with CenterPoint Houston, the " Registrants "), we submit via EDGAR for review by the
Division of Corporation Finance of the United States Securities and Exchange Commission (the " Commission ") the accompanying
Amendment No. 1 (including certain exhibits) (" Amendment No. 1 ") to the Registrants' above-referenced
Registration Statement on Form SF-1 (the " Registration Statement ") which is being filed simultaneously with this
response letter. Amendment No. 1 reflects the Registrants' responses to the comments received from the staff of the Commission
(the " Staff ") contained in the Staff's letter dated July 18, 2025, and certain other updated information.
For your convenience, the Registrants are providing to the Staff a supplemental copy of Amendment No. 1 marked to indicate the changes
from the Registration Statement that was filed on June 20, 2025.

 Set forth below are the Registrants'
responses to the Staff's comments. The Registrants' responses below are preceded by the Staff's comments for ease
of reference. Capitalized terms used but not defined herein have the meanings given to them in Amendment No. 1.

 Registration Statement on Form SF-1

 Cover Page

 1. We note that the system restoration bonds will be issued in multiple tranches. Please revise your cover
page and your form of prospectus as necessary to identify the tranche designations being offered. Refer to Item 501(b)(2) of
Regulation S-K and Item 1102(b) of Regulation AB.

 RESPONSE :
The Registration Statement has been revised to clarify that two tranches of the system restoration bonds will be offered pursuant to the
prospectus included in the Registration Statement, which tranches will be designated as "Tranche A-1" and "Tranche A-2."

 Cautionary Statement Regarding Forward-Looking Information, page vi

 2. We note your statement on page vi that you undertake no obligation to update or revise any forward-looking
statements. This disclaimer does not appear to be consistent with your disclosure obligations. Please revise to clarify that you will
update this information to the extent required by law.

 RESPONSE :
The Registrants hereby confirm that they will update the forward-looking statements included in the prospectus to the extent required
under applicable law, as stated at the bottom of page vi of Amendment No. 1.

 Prospectus Summary of Terms

 Servicing Compensation, page 15

 3. We note your disclosure that, in addition to receiving an annual servicing fee, the servicer will be
entitled to receive reimbursement for its out-of-pocket costs for external accounting and legal services. We are unable to locate additional
disclosure in the form of prospectus with respect to the expected amount of such out-of-pocket expenses or whether there are any restrictions
or limits on such out-of-pocket expenses. Please revise. Refer to Item 1113(c) of Regulation AB.

 RESPONSE :
The financing order permits the servicer to recover certain third-party costs relating to servicing the system restoration bonds in addition
to the servicing fee. There is no limit in the financing order on the amount of the out-of-pocket expenses authorized to be recovered,
and such expenses will be recovered as ongoing qualified costs through the collection of the system restoration charges and paid to the
servicer in accordance with the payment waterfall in the indenture. The Registration Statement has been revised to clarify the extent
of such costs and to include a description of the authorized out-of-pocket expenses under the servicing agreement, as well as an estimate
of such annual expenses. Please see pages 15 and 125 of Amendment No. 1 for revised disclosure concerning the servicer's
out-of-pocket expenses.

 2

 Risk Factors

 Changes to billing and collection practices might reduce the
value of your investment in the system restoration bonds, page 25

 4. We note your disclosure that the servicer may change billing and collection practices and that such
changes could limit the issuing entity's ability to make scheduled payments on the system restoration bonds. These statements appear to
be inconsistent with the statements elsewhere in the prospectus that the true-up mechanism will "ensure" the billing of amounts
sufficient to timely provide all payments on the system restoration bonds. As examples only, please refer to the disclosures under the
headings "Statutory true-up mechanism for payment of scheduled principal and interest" on page 9, "Credit Enhancement"
on page 14, and "The System Restoration Charges" on page 74. Please revise here and throughout the prospectus as
necessary to reconcile these statements.

 RESPONSE :
The Registration Statement has been revised to delete the risk factor "Changes to billing and collection practices might reduce
the value of your investment in the system restoration bonds."

 CenterPoint Houston or its affiliates may cause the issuance,
by another subsidiary or affiliated entity…, page 34

 5. We note your disclosure here that any new issuance of system restoration bonds or similar bonds "by
another subsidiary or affiliated entity of CenterPoint Houston" could cause reductions or delays in payment of principal and interest
on the system restoration bonds. We also note, however, that the system restoration property collateralizing the bonds will be transferred
to the issuing entity, which is a bankruptcy-remote special purpose vehicle. Please revise to explain how bonds issued by a different
entity could impact payments on the systems restoration bonds offered by this prospectus.

 RESPONSE :
Under PUCT regulations, REPs issue a single bill to retail customers purchasing electricity from the REP. This single bill includes all
charges related to purchasing electricity from the REP, transmission and distribution services from CenterPoint Houston, the applicable
system restoration charges and any other charges authorized by the PUCT, which may include future system restoration charges or other
utility rate tariff charges in connection with future system restoration bonds or other utility rate tariff bonds issued by an affiliate
of CenterPoint Houston. Each REP will collect the combined amount from its retail customers and will remit the appropriate portion of
such combined amount to CenterPoint Houston, the servicer of the system restoration bonds offered pursuant to the prospectus included
in the Registration Statement, the servicer of any future system restoration or other utility rate tariff bonds, if any, and to other
parties, if any, entitled to receive a portion of such amount. The servicer will not segregate the system restoration charges from the
other funds it collects from REPs or its general funds. The system restoration charges will be segregated only when the servicer pays
them to the trustee, which remittance shall occur no later than the second servicer business day after such payments are estimated to
have been received. Please see "Risk Factors - Risks associated with potential bankruptcy proceedings of the seller or the
servicer - The Servicer will commingle the system restoration charges with other revenues it collects, which might obstruct access
to the system restoration charges in case of the servicer's bankruptcy and reduce the value of your investment in the system restoration
bonds" beginning on page 28 of Amendment No. 1.

 3

 In the event a REP does not pay in full
all amounts owed under any bill, including system restoration charges for the system restoration bonds, the amount remitted to the trustee
will be apportioned between the system restoration charges and other fees and charges (including amounts billed and due in respect of
system restoration charges or other utility rate tariff charges associated with bonds issued under future financing orders). If a dispute
arises with respect to the allocation of such charges or other delays occur on account of the administrative burdens of making such allocation,
there is a risk of reductions or delays in payment of principal and interest on the system restoration bonds.

 The Registration Statement has been
revised on pages 30 and 35 of Amendment No. 1 to clarify how bonds issued by a different bankruptcy-remote entity could impact
payments on the system restoration bonds offered by the prospectus included in the Registration Statement, including how the apportionment
of fees and charges would be expected to occur.

 The Depositor, Seller, Initial Servicer and Sponsor

 Credit Policy; Billing Process; Collections Process, page 65

 6. We note that CenterPoint Houston, as servicer, may institute changes to billing and collection practices
that would affect the servicing of the system restoration property. Please revise to describe what changes may be made and whether (and
if so, how) you will notify investors of any such changes to servicing practices that may impact bond payments and the true-up adjustments,
if applicable.

 RESPONSE :
Subject to PUCT standards and regulations, CenterPoint Houston may from time to time make changes to its customary billing and
collection practices to enhance its ability to make timely recovery of amounts billed. CenterPoint Houston may also be required to
make changes to its customary practices to comply with or address legislative or regulatory developments, including mandates from
the State of Texas or the PUCT. For example, the PUCT has in recent years (i) imposed a temporary moratorium on executing
disconnects of electric service for non-pay orders from REPs and (ii) temporarily required CenterPoint Houston to suspend wires
charges to REPs with respect to certain retail customers. Although CenterPoint Houston is unable to predict future changes to the
PUCT's standards and regulations applicable to CenterPoint Houston or the REPs, the Registration Statement has been revised on
pages 23 and 67 of Amendment No. 1 to offer some examples of past changes to CenterPoint's billing and collection
processes.

 The servicing agreement and the indenture
will obligate the Registrants to provide certain notices to the trustee and the bond rating agencies and to make certain information regarding
the system restoration bonds publicly available on a website associated with CenterPoint Houston.

 4

 Under Section 3.01(b)(ii) of
the servicing agreement, CenterPoint Houston will be required to provide immediate notice to the trustee and the bond rating agencies
of any changes in law or PUCT regulations that would have a material adverse effect on CenterPoint Houston's ability to perform
its duties under the servicing agreement. In addition, Section 3.07(g)(vi) of the indenture will obligate the Registrants to
file a Form 8-K (posted to the CenterPoint Energy, Inc. website) with respect to any material legislative enactments or regulatory
orders or rules directly relevant to the system restoration bonds. The Registrants believe that any State of Texas or PUCT mandated
change to servicing practices that impacts bond payments or the periodic true-up adjustments would be addressed through these disclosure
requirements.

 In addition, Section 3.07(g)(vii) of
the indenture will require website posting of the following additional information with respect to the servicing of the system restoration
bonds:

 · each Form 10-K filing (including the servicing compliance certificates and auditor attestations);

 · each Form 10-D filing (including the semi-annual servicer certificate, which reflects billing, collection
and remittance information);

 · each monthly servicer certificate (which reflects billing, collection and remittance information); and

 · each true-up adjustment filing with the PUCT (which would reflect any changes to projected charge-off
rates and allocation of system restoration charges among customer classes).

 These website disclosure requirements
are identified under the heading "Description of the System Restoration Bonds-Website" on pages 90–91 of
Amendment No. 1.

 Description of the System Restoration Bonds

 The Security for the System Restoration Bonds, page 83

 7. We note that the trust property will include rights under certain agreements, including an intercreditor
agreement executed in connection with the servicing agreement. We also note the disclosure on page 119 under the heading "The
Servicing Agreement - Servicing Procedures" that the servicer will have certain obligations pursuant to "any future intercreditor
agreement." It is unclear to us whether there is an existing intercreditor agreement that will govern the rights of the bondholders
or if this disclosure is referring to a hypothetical future intercreditor agreement. Please revise your prospectus throughout as necessary
to clarify whether there will be an intercreditor agreement entered into at the time of issuance of the bonds and whether additional intercreditor
agreements may be executed by a transaction party in the future. For both circumstances, please also revise your disclosure to describe
how such agreement would impact the rights of the bondholders in this offering.

 RESPONSE :
The Registrants hereby confirm that there is not an existing intercreditor agreement and that an intercreditor agreement is not being
executed in connection with the offering of the system restoration bonds pursuant to the prospectus included in the Registration Statement.
CenterPoint Houston has covenanted in the sale agreement that the execution and delivery of an intercreditor agreement is a condition
precedent to the sale of future system restoration bonds or other utility tariff bonds by an affiliated entity of CenterPoint Houston.
The Registration Statement has been revised on pages 7, 30, 35, 70 and 84 of Amendment No. 1 to clarify such matters and to
describe how such an agreement could impact the rights of the holders of the system restoration bonds.

 5

 Description of the System Restoration Bonds

 The Collection Account for the System Restoration Bonds, page 84

 8. We note your disclosure that, in addition to the system restoration property, the bonds will also be
secured by "the collection account for the system restoration bonds and all subaccounts of the collection account." Please
confirm whether any of the underlying collateral will consist of securities for purposes of Securities Act Rule 190.

 RESPONSE :
The Registrants hereby confirm that none of the underlying collateral will consist of securities for the purposes of Rule 190 under
the Securities Act of 1933, as amended (the "Securities Act").

 The Sale Agreement

 CenterPoint Houston's Covenants, page 113

 9. Your prospectus disclosure appears to indicate that CenterPoint Houston may also enter into an intercreditor
agreement in connection with a sale agreement, and that the issuing entity may be a party to such agreement. Please clarify whether the
intercreditor agreement that may be entered into by CenterPoint Houston in connection with a sale agreement is the same intercreditor
agreement contemplated in the disclosures referenced on pages 83 and 119 of your prospectus and in comment 7 of this letter. If it
is not, please revise your disclosure as necessary to describe its purpose and the impact that such intercreditor agre