DOCKET NO. 13A-0773EG DIRECT TESTIMONY AND EXHIBITS OF LEE E. GABLER

Transcription

1 IN THE MATTER OF THE APPLICATION OF PUBLIC SERVICE COMPANY OF COLORADO FOR APPROVAL OF ITS ELECTRIC AND NATURAL GAS DEMAND-SIDE MANAGEMENT (DSM PLAN FOR THE CALENDAR YEAR 0 AND TO CHANGE ITS ELECTRIC AND GAS DSM COST ADJUSTMENT RATES EFFECTIVE JANUARY, 0 DOCKET NO. A-0EG DIRECT TESTIMONY AND EXHIBITS OF LEE E. GABLER JULY, 0

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO * * * * * IN THE MATTER OF THE APPLICATION OF PUBLIC SERVICE COMPANY OF COLORADO FOR APPROVAL OF ITS ELECTRIC AND NATURAL GAS DEMAND-SIDE MANAGEMENT (DSM PLAN FOR THE CALENDAR YEAR 0 AND TO CHANGE ITS ELECTRIC AND GAS DSM COST ADJUSTMENT RATES EFFECTIVE JANUARY, 0 DOCKET NO. A- 0EG DIRECT TESTIMONY AND EXHIBITS OF LEE E. GABLER ON BEHALF OF PUBLIC SERVICE COMPANY OF COLORADO JULY, 0

3 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO * * * * * IN THE MATTER OF THE APPLICATION OF PUBLIC SERVICE COMPANY OF COLORADO FOR APPROVAL OF ITS ELECTRIC AND NATURAL GAS DEMAND-SIDE MANAGEMENT (DSM PLAN FOR THE CALENDAR YEAR 0 AND TO CHANGE ITS ELECTRIC AND GAS DSM COST ADJUSTMENT RATES EFFECTIVE JANUARY, 0 DOCKET NO. A- 0EG DIRECT TESTIMONY AND EXHIBITS OF LEE E. GABLER TABLE OF CONTENTS SECTION PAGES I. INTRODUCTION... II. 0 DSM PLAN OVERVIEW... III. ENERGY SAVINGS AND DEMAND REDUCTION GOALS... IV. ELECTRIC AND GAS DSM BUDGETS FOR 0... V. COST EFFECTIVENESS... VI. MEASUREMENT AND VERIFICATION...

4 LIST OF EXHIBITS Exhibit No. LEG- 0 DSM Biennial Plan Exhibit No. LEG- 0/0-Day Notice List for 0 0 Exhibit No. LEG- Exhibit No. LEG- Electric DSMCA Tariff Gas DSMCA Tariff

5 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO * * * * * N THE MATTER OF THE APPLICATION OF PUBLIC SERVICE COMPANY OF COLORADO FOR APPROVAL OF ITS ELECTRIC AND NATURAL GAS DEMAND-SIDE MANAGEMENT (DSM PLAN FOR THE CALENDAR YEAR 0 AND TO CHANGE ITS ELECTRIC AND GAS DSM COST ADJUSTMENT RATES EFFECTIVE JANUARY, 0 DOCKET NO. A- 0EG DIRECT TESTIMONY AND EXHIBITS OF LEE E. GABLER 0 I. INTRODUCTION Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. A. My name is Lee E. Gabler. My business address is Nicollet Mall, Minneapolis, MN. Q. BY WHOM ARE YOU EMPLOYED AND IN WHAT POSITION? A. I am employed by Xcel Energy Services Inc., a wholly-owned subsidiary of Xcel Energy Inc., the parent company of Public Service Company of Colorado. My job title is Director, Demand Side Management and Renewable Operations. Q. ON WHOSE BEHALF ARE YOU TESTIFYING IN THE PROCEEDING? A. I am testifying on behalf of Public Service Company of Colorado ( Public Service or the Company.

6 0 0 Q. HAVE YOU INCLUDED A DESCRIPTION OF YOUR QUALIFICATIONS, DUTIES, AND RESPONSIBILITIES? A. Yes. A description of my qualifications, duties, and responsibilities is included as Attachment A. Q. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? A. The purpose of my testimony is to present the Company s plans for electric and gas demand-side management ( DSM in Colorado for the calendar year 0. I sponsor the detailed 0 Colorado DSM Plan ( 0 Plan or Plan as Exhibit No. LEG-. Exhibit No. LEG- details the components of our proposed portfolio of gas and electric DSM programs, including our benefitcost analysis using forecast participation rates and avoided costs and planning assumptions. I present our proposed energy and demand savings targets and budgets for the 0 gas and electric DSM Plan. I discuss the determination of cost effectiveness, and I present our plan for measurement and verification. Q. WHAT ARE THE SPECIFIC APPROVALS THE COMPANY IS SEEKING FROM THE COMMISSION IN THIS PROCEEDING? A. Public Service is asking the Commission to:. Approve the electric and gas DSM portfolios as set forth in Exhibit No. LEG-, with recognition that the Company retains the flexibility to modify the portfolios within the parameters agreed to in the Stipulation and Settlement Agreement approved by the Commission in Decision No. R0- in Docket No. 0A-EG and reaffirmed in Decision No. R0- in Docket No. 0A-

7 0 0 EG, Decision No. C-0 in Docket No. 0A-EG. and Decision No. R- in Docket No.A-EG.. Approve our proposed electric demand reduction goals for 0.. Approve the proposed electric DSM budget for the calendar year 0.. Approve the gas DSM budget for the calendar year 0 and the associated energy savings targets proposed by the Company.. Approve the avoided costs used in the analysis of the electric and gas cost-effectiveness as reflected in Appendix C to the Plan.. Approve the technical assumptions, including the deemed savings for prescriptive programs set forth in the Technical Reference Manual included as Appendix G to Exhibit No. LEG- and the net-to-gross factors for each DSM product that are set forth in the Planning Assumptions section of the 0 Plan.. We are also asking to authorize the Company to file revised electric and gas DSMCA tariffs to put into effect new rates effective January, 0 in the form attached as Exhibit Nos. LEG- and, respectively, sufficient to recover the electric and gas DSM budgets approved in this proceeding for the Company s proposed 0 DSM portfolios. In the case of the electric DSMCA, the Commission has previously authorized the Company to recover on a current basis, through the combination of base rates and the DSMCA, 00 percent of the credits it forecasts will be paid to customers under the Interruptible Service Option Credit ( ISOC during the DSM program year as well as all costs paid to EnerNoc under the third-party demand response

8 0 0 program. See Advice Letter, dated December, 00, Advice Letter, dated April, 00, and Advice Letter dated July, 00 (all of which the Commission allowed to take effect by operation of law, and Decisions No. R0- and C0- in Docket No. 0AL-E. II. 0 DSM PLAN OVERVIEW Q. PLEASE PROVIDE AN OVERVIEW OF THE COMPANY S 0 DSM PLAN FILING. A. We are filing this combined 0 natural gas and electric DSM plan in accordance with Commission Decision Nos. C-0 and C-0 issued in Docket No. 0A-EG and Rules 0 to 0 of the Commission s Rules Regulating Gas Utilities and Pipeline Operators ( the Gas DSM Rules. A copy of the proposed 0 DSM plan ( Plan is attached to my testimony as Exhibit No. LEG-. The majority of the DSM programs and products the Company has proposed are the same as those that have been implemented since 00. However we have updated our avoided costs and technical assumptions for purposes of the 0 plan to reflect more current data, third party review of our technical assumptions and the results of the comprehensive product evaluations conducted during 0. We are seeking approval of our updated avoided costs and technical assumptions by this Application. Decision No. C-0 established DSM electric energy savings goals for Public Service for the years 0 through 00. The Company has designed its proposed electric DSM plan for 0 to meet the established

9 0 0 electric energy savings goals for 0 of GWh. No demand savings goals were established in the Decision. The Company s 0 DSM filing also includes DSM products directed at saving natural gas. These products were developed consistent with the Commission s Gas DSM Rules adopted in Decision No. C0-0 issued in Docket No. 0R-G, as modified through waivers granted initially in Decision No. C0-00 issued in Docket No. 0A-0E and reaffirmed in Decision Nos. C-0 and C-0. The Company seeks approval of the proposed expenditures and associated energy savings targets applicable to its natural gas DSM Plan as part of this Application. Q. WHAT MAJOR CHANGES FROM THE 0/ PLAN HAVE BEEN INCORPORATED INTO THE 0 PLAN? A. We have included all changes and additions to the 0 Plan that were made pursuant to the 0/0-day notice process currently in place for making modifications to our plans. Exhibit No. LEG- is a list of each of the 0/0- day notices provided since the beginning of 0. Q. IS THE COMPANY PROPOSING TO ADD OR REMOVE OTHER PRODUCTS OR MEASURES THAT HAVE NOT BEEN THE SUBJECT OF A 0/0-DAY NOTICE IN 0? A. Yes, in addition to the modifications made through 0/0-day notices, we are proposing to add or remove the following products and measures for the 0 plan:

10 0 0 Measures Added Building Tune Up Measure Recommissioning; Bathroom and Kitchen Aerators Energy Efficient Showerheads; Anti-Sweat Heater Controls Cooling Efficiency; Electronically Commutated Motors For Furnace Fans Heating System Rebates; Online Energy Feedback Energy Feedback Pilot; Bathroom and Kitchen Aerators and Energy Efficient Showerheads School Education Kits; and LED Parking Garage Retrofit and New Construction Lighting Efficiency and Small Business Lighting. Measures Removed Rebates for Plan B Boilers Heating Efficiency; Advanced Evaporative Cooling Cooling Efficiency; Standard Tank Water Heater Rebates 0. and 0. Energy Factor Water Heater Rebate; and Furnace Rebates With Less Than % Annual Fuel Utilization Efficiency Heating System Rebates. Q. PLEASE SUMMARIZE THE DSM PLAN ATTACHED AS EXHIBIT NO. LEG-. A. As shown in Exhibit No. LEG-, for 0 Public Service is proposing a comprehensive portfolio of electric and gas DSM Programs that are expected to deliver approximately. GWh of electric energy savings;. MW of

11 0 0 electric demand reduction; and, dekatherms of natural gas savings in 0. For 0, the Company is proposing an electric DSM budget of $. million and a gas DSM budget of $. million. The 0 Plan includes the following Programs: Residential Electric Program: o electric products with energy savings targets totaling. GWh and a combined budget of $. million; Low-Income Electric Program: o electric products with energy savings targets totaling. GWh and a combined budget of $. million; Business Electric Program: o electric products with energy savings targets totaling. GWh and a combined budget of $. million; Residential Gas Program: o gas products with energy savings targets totaling,0 dekatherms and a combined budget of $. million; Low-Income Gas Program: o gas products, with energy savings targets totaling, dekatherms and a combined budget of $. million; Business Gas Program: o gas products with energy savings targets totaling, dekatherms and a combined budget of $. million;

12 0 0 In addition, the portfolio includes Indirect Products and Services which support the direct savings programs listed above. These indirect products and services are as follows: Indirect Products: Education/Market Transformation: o combined electric/gas products with a combined budget of $. million; Indirect Services: Planning and Research and Pilot Products: o non-customer facing internal services with a combined budget of $. million. Within the Product Development area, there are pilot products, two of which have projected savings of. GWh and, Dth based upon a combined electric/gas budget of $. million. Q. DOES THE PROPOSED 0 DSM PLAN PROVIDE SAVINGS OPPORTUNITIES FOR ALL CLASSES OF ELECTRIC CUSTOMERS AS REQUIRED BY 0-.-0(, C.R.S. AND FOR BOTH COMMERCIAL AND RESIDENTIAL GAS SALES CUSTOMERS AS REQUIRED UNDER THE COMMISSION S GAS RULES? A. Yes, the Plan has electric and gas programs applicable to residential, lowincome, commercial, and industrial customers, other than those who receive gas transportation service. The Plan includes products for both existing homes and buildings and new construction. It addresses the significant enduses for both residential and business customer classes.

13 0 0 Q. DOES THE COMPANY EXPECT TO CONTRACT TO THIRD PARTIES FOR SOME OF ITS PROGRAM IMPLEMENTATION? A. Yes. The Company utilizes third party implementers for over 0 of its programs. During the 0 period the Company expects to competitively bid contracts for its ENERGY STAR New Homes and Refrigerator Recycling programs. Q. HOW DOES THE COMPANY ENSURE CONTRACTED SERVICES ARE COMPETITIVE? A. Public Service issues competitive request for proposals ( RFP to obtain bids from a wide variety of sources as the preferred method of selecting service providers. We evaluate all bids in two phases, the Pre-qualification phase and the Bid Evaluation phase. The Pre-qualification phase ensures that RFP respondents meet minimum requirements to conduct business on our behalf. Respondents are evaluated on Safety, Financial Health, Terms & Conditions Adoption, and Prior Experience. These are also factors in the Bid Evaluation phase, but have lower weightings due to the initial evaluation. This helps to ensure the business risk of contractor non performance to the Company is as low as possible. The Bid Evaluation phase is based upon up to factors and is the phase where the risk of the supplier performing is weighed against the cost to perform. These factors are Cost, Ability to Perform, Safety, Financial Health, Terms & Conditions Adoption, Project Specific Needs, Diversity, and Green Business Practice.

14 The following table shows whether programs are defined as having third party implementers, whether they are competitively bid or sole sourced and when those contracts are expected to be awarded. Third-Party Products Not being bid in 0 Table Expected RFPs for 0 (Product Type of Contract Competitive Bid or Sole Sourced ENERGY STAR New Homes Competitive Bid Refrigerator Recycling Competitive Bid Commercial Refrigeration Competitive Bid (0 Computer Efficiency Sole Sourced DEPCACC Competitive RFP (0 Energy Analysis (Onsite Audits Competitive Bid (0 Energy Efficient Showerheads Sole Sourced Energy Feedback Pilot - Residential Sole Sourced Energy Savings Kits Competitive Bid (0 Home Lighting Competitive Bid (0 Home Performance with ENERGY STAR Competitive Bid (0 Multi Family Weatherization Sole Sourced New Construction Competitive Bid (0 Non-Profit Energy Efficiency Sole Sourced Peak Savings Competitive Bid (00 Pool Pumps Competitive Bid (0 Residential Home Energy Audit Competitive Bid (0 School Education Kits Competitive Bid (0 Segment Efficiency Competitive RFP (0 Single Family Weatherization Sole Sourced Small Business Lighting Competitive Bid (0 Q. ARE YOU PROPOSING ANY PILOT PROGRAMS IN THE PLAN? A. Yes. The Company proposes to continue in effect the Energy Feedback Pilot, The Community Energy Efficiency Planning Pilot, Electric Vehicle Charging 0

15 0 0 Station Pilot and the In Home Smart Device Pilot for 0. The Company proposes to launch pilots for an Energy Feedback Pilot directed at business customers in 0. Q. HOW WILL THE COMPANY TREAT PILOTS IN CALCULATION OF THE FINANCIAL INCENTIVE? A. Three of the five pilots the Company proposes to offer in 0 are considered market transformation and will therefore be treated consistent with the Commission s directives in Paragraphs and of Decision No. C-0 issued in Docket No. 0A-EG. The Energy Feedback Pilot Residential and the Energy Feedback Pilot Business are market transformation programs for which the Company will continue to claim energy savings. The Company has therefore detailed in its Plan how its efforts under this program are linked to the expected energy savings and has explained how the measurement and verification of such savings will be accomplished. The Company has calculated the Total Resource Cost ( TRC for the Energy Feedback Pilot which is reflected in the Plan. TRC measures the net costs of a demand-side management program as a resource option based on the total costs of the program, including both the participants' and the utility's costs For the Community Energy Efficiency Planning Pilot and the In-Home Smart Device Pilot, the Company will not attempt to measure any energy savings for the purpose of calculating the incentive stemming from its efforts under this pilot, and will therefore be applying a presumptive TRC value of for this pilot.

16 0 0 The Electric Vehicle Charging Stations pilot is not a market transformation activity, nor will the Company measure savings stemming from this pilot. Since the pilot is not a market transformation activity and will not be claiming savings, the Company will treat the expense within the indirect product development budget and be included in the overall portfolio TRC. Q. WHICH OTHER PRODUCTS INCLUDED IN THE PLAN ARE CONSIDERED MARKET TRANSFORMATION AND THEREFORE WILL HAVE A PRESUMPTIVE TRC OF.0 SO AS TO NOT HAVE AN ADVERSE EFFECT ON THE CALCULATION OF FINANCIAL INCENTIVES? A. Other products that the Company proposes should be considered as market transformation and therefore may have a presumptive TRC of.0 are: Business Energy Analysis, Residential Home Energy Audits, Energy Efficiency Financing and Residential and Business Consumer Education. Q. PLEASE GUIDE THE COMMISSION THROUGH THE PROPOSED 0 PLAN DOCUMENTATION YOU HAVE SUBMITTED AS EXHIBIT NO. LEG-. A. The proposed 0 Plan follows the same general outline that was used for purposes of the 0/ Biennial Plan. The 0 Plan is divided into major sections relating to the respective customer segments, including Business, Residential, Low-Income, and Indirect Programs. It also includes a section on Planning Assumptions, which contains forecasted participation rates and technical assumptions, and a Benefit-Cost Analysis section. Each customer

17 program includes detailed descriptions of the products that make up that program. 0 0 Each product description includes the following information: Description Goals, Participants & Budgets Application Process Marketing Objectives, Goals, & Strategy Product Specific Policies Stakeholder Involvement Rebate Levels Lastly, the Plan includes the following Appendices: Appendix A - Acronyms Appendix B Product Ranking Appendix C Avoided Costs Appendix D Budget Categories Appendix E Natural Gas DSM Dollar per Therm and Acknowledgement of Loss Revenue Methodology Appendix F Technical Assumptions and Net to Gross Review Appendix G - Technical Reference Manual, including Technical Assumptions Used for Prescriptive Programs Deemed Savings

18 0 0 III. ENERGY SAVINGS AND DEMAND REDUCTION GOALS Q. WHAT IS THE LEVEL OF ELECTRIC DSM ENERGY SAVINGS THAT THE COMMISSION APPROVED IN DOCKET NO. 0A-EG FOR 0? A. The energy savings goals established by the Commission in Docket No. 0A- EG were reflected in a table set forth at page, paragraph of Decision C-0. Here, the Commission approved an energy savings goal of GWh for 0. Q. WHAT IS THE LEVEL OF GAS DSM SAVINGS THAT ARE REQUIRED BY THE COMMISSION S RULES? A. Rather than identifying minimum levels of gas DSM savings, Commission Rule (h(i establishes a minimum expenditure target for gas DSM programs. The Rule states: The utility s annual expenditure target for DSM programs shall be, at a minimum, two percent of a natural gas utility s base rate revenues, (exclusive of commodity costs, from its sales customers in the -month calendar period prior to setting the targets, or one-half of one percent of total revenues from its sales customers in the -month calendar period prior to setting the targets, whichever is greater. For calendar year 0, Public Service s gas base rate revenues are expected to be $,,0. Two percent of base rate revenues equals $,,. During this same period, our total gas revenue was $,,. One half of one percent of total gas revenue equals $,0,. According to the Commission s Rule, Public Service is required to propose a gas DSM plan that, at a minimum, is funded at $,, annually.

19 Q. WHAT IS THE LEVEL OF ANNUAL GAS DSM EXPENDITURES THE COMPANY HAS INCLUDED IN ITS 0 PLANS PROPOSED IN THIS PROCEEDING? A. Public Service is proposing a gas DSM budget equal to $. million for 0. Public Service has developed Gas DSM Savings plans that are designed to save, dekatherms in 0. The estimated annual level of natural gas energy savings expressed in dekatherms per million dollars of expenditures for 0 is 0,0 Dth per $M, which is higher than 0 actual results of $, Dth per $M. 0 0 IV. ELECTRIC AND GAS DSM BUDGETS FOR 0 Q. WHAT ARE THE PROPOSED ELECTRIC DSM BUDGETS FOR 0? A. Our forecasted electric DSM budget for 0 is $. million. This reflects an increase of.% over the electric DSM budget of $.0 million that was approved for 0. Q. HOW WERE THE 0 ELECTRIC DSM BUDGETS DERIVED? A. At the beginning of our planning process, products are assigned individual energy savings goals based on a variety of inputs. To build the associated product budget, we analyze historical product performance and cost trends -- including any rebate level modifications, then apply this information to the forecasted participation rates to determine the base budget. Then we factor in any additional expenses that might be needed for specific marketing efforts. The base budget plus additional efforts equals the total product budget. This process is consistent with the way we have developed our DSM

20 budgets in the past and is reflected in the Plan document attached to my testimony as Exhibit No. LEG-. Q. WHAT ARE THE PROPOSED NATURAL GAS BUDGETS FOR 0? A. As discussed above under the section of my testimony dealing with natural gas goals, we are proposing to spend $. million during 0 on natural gas DSM programs. The gas budgets were developed in the same way as we developed the electric DSM budget for V. COST EFFECTIVENESS Q. HOW IS THE COMPANY MEASURING COST-EFFECTIVENESS OF ITS GAS AND ELECTRIC DSM PROGRAMS? A. For both electric and gas cost effectiveness, the Company uses the Modified TRC, which is consistent with 0--0(, C.R.S. and the Commission s Gas DSM Rules. The benefit side of the benefit-cost equation for electric includes avoided generation, transmission, distribution, capacity, and energy costs, valuation of emissions, O&M savings, and rebates and incentives received by the participants and/or vendors. For Gas, the benefit side of the equation includes the commodity cost of gas, avoided variable O&M costs, and demand savings calculated as avoided reservation costs, as well as O&M savings, and rebates and incentives received by the participants and/or vendors. In addition, for electric DSM, other than low-income, a 0% nonenergy benefits adder is applied to the system benefits in accordance with Paragraph of Decision No. C0-00. For Gas DSM, other than lowincome, a combined emissions and non-energy benefits adder of % is

21 0 0 applied to the benefits in accordance with Gas DSM Rule (i(i. For lowincome electric and gas DSM, this adder is increased to % for purposes of screening for cost effectiveness in accordance with paragraph of Decision No. C-0. The cost side of the benefit-cost equation for both gas and electric consists of all the utility costs necessary to administer the DSM programs (including rebates paid plus the participants incremental capital costs and any O&M costs of the more efficient measure compared to the standard or baseline measure. Q. ARE ANY OF THE PRODUCTS IN THIS ELECTRIC OR GAS DSM PLAN NON COST EFFECTIVE? A. Yes, at the product level Heating System Rebates fails the gas Modified TRC, High Efficiency Air Conditioning fails the electric Modified TRC, and Water Heater Rebate fails both gas and electric Modified TRC. Q. WHY HAS THE COMPANY CHOSEN TO INCLUDE THESE PRODUCTS IN THE DSM PORTFOLIO? A. The Company has sought to maintain a stable gas DSM portfolio in light of low natural gas prices to ensure the continuity of products for customers and trade partners and to ensure that customers who want to reduce their gas bills can receive the Company s assistance to do so. Heating and water heating represent some of the core systems of a household and while low natural gas prices and high energy codes have reduced some of the benefits of the energy savings these products are critical to creating a comprehensive DSM portfolio. Similarly High Efficiency Air Conditioning is a core system of a

22 household and critical to a comprehensive DSM portfolio, but has seen some of the benefits reduced due to lower avoided costs and higher energy codes.

23 0 Q. DOES THE COMPANY PROPOSE TO USE THE SAME AVOIDED COSTS ASSUMPTIONS USED FOR PURPOSES OF DETERMINING EACH PRODUCT S COST EFFECTIVENESS AT THE OUTSET TO CALCULATE THE LEVEL OF NET ECONOMIC BENEFITS ACHIEVED AFTER THE FACT? A. Yes Q. WHAT ARE THE RESULTS OF THE FORECASTED COST EFFECTIVENESS TESTS FOR THE PROGRAMS OF THE 0/ PLAN? A. For 0, the total electric DSM portfolio has a forecasted TRC ratio of.. The program forecasted TRCs are: Residential Electric Program:. Low-Income Electric Program:. Business Electric Program:. The total gas DSM portfolio has a forecasted TRC ratio of.. The program forecasted TRCs are: Residential Gas Program:.0 Low-Income Gas Program:. Business Gas Program:. 0 VI. MEASUREMENT AND VERIFICATION Q. PLEASE DESCRIBE THE MEASUREMENT AND VERIFICATION THE COMPANY PROPOSES FOR 0. A. For 0, the Company will continue the same general processes for ongoing measurement and verification that have been in effect since 00.

24 These methodologies are detailed in the Indirect Section of the Plan under Evaluation, Measurement, and Verification. In addition the Company will perform several Comprehensive Program Evaluations during 0. Two products have been identified for evaluation in 0: Energy Management Systems and Low Income Multi-Family Weatherization. The primary 0 0 objectives of the comprehensive evaluations are to assess customer satisfaction with the DSM product and to assess whether any changes that should be made to the product processes or to the net-to-gross ( NTG ratios going forward. Additionally the Company will conduct a Portfolio Technical Assumptions Evaluation every two years. This evaluation is designed to allow for thorough examination of the technical assumptions, inputs, baselines, and calculators used across the entire program portfolio. Q. DID THE COMPANY CONDUCT A COMPREHENSIVE REVIEW OF ALL TECHNICAL ASSUMPTIONS USED TO DETERMINE ENERGY SAVINGS? A. Yes, to meet the Company s obligations under the Settlement Agreement in Docket No. A-EG, the Company engaged a third-party to perform an engineering, literature and benchmarking review of the technical assumptions and net-to-gross ratios it uses to determine energy savings in the 0- DSM Plan. This third-party report is included as LEG- in Appendix F, along with the Company s response to the report recommendations. Q. DOES THIS CONCLUDE YOUR TESTIMONY? A. Yes, it does. 0

25 Attachment A STATEMENT OF QUALIFICATIONS Lee E. Gabler I graduated from St. John s University in Collegeville, MN with a Bachelor of Science degree in Business Administration. I have been employed by Xcel Energy (previously Northern States Power Company for years. I currently serve as the Director, Demand Side Management and Renewable Operations. In this role I am responsible for the implementation and financial management of energy efficiency, load management and renewable products for business and residential customers. I have been in this role since July, 00. From to 00, I was the Director, Credit and Collections for Northern States Power/Xcel Energy. From 00 to 00 I was the Director, Customer Contact Centers for Xcel Energy.