Exhibit 18.1


November 9, 2005

CenterPoint Energy Resources Corp.
Houston, Texas 77002

Dear Sirs/Madams:

         At your request, we have read the description included in your
Quarterly Report on Form 10-Q to the Securities and Exchange Commission for the
quarter ended September 30, 2005, of the facts relating to the change in the
date of annual goodwill impairment tests under Statement of Financial Accounting
Standards No. 142, "Goodwill and Other Intangible Assets". We believe, on the
basis of the facts so set forth and other information furnished to us by
appropriate officials of the Company, that the accounting change described in
your Form 10-Q is to an alternative accounting principle that is preferable
under the circumstances.

         We have not audited any consolidated financial statements of
CenterPoint Energy Resources Corp. and its consolidated subsidiaries as of any
date or for any period subsequent to December 31, 2004. Therefore, we are unable
to express, and we do not express, an opinion on the facts set forth in the
above-mentioned Form 10-Q, on the related information furnished to us by
officials of the Company, or on the financial position, results of operations,
or cash flows of CenterPoint Energy Resources Corp. and its consolidated
subsidiaries as of any date or for any period subsequent to December 31, 2004.

Yours truly,

/s/ Deloitte & Touche LLP
Houston, Texas