BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) DIRECT TESTIMONY MELISSA L. OSTROM.

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1 BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION IN THE MATTER OF SOUTHWESTERN PUBLIC SERVICE COMPANY S APPLICATION REQUESTING APPROVAL TO RETIRE AND ABANDON ITS PLANT X GENERATING STATION UNIT, PLANT X GENERATING STATION UNIT, AND CUNNINGHAM GENERATING STATION UNIT, AND DETERMINATION OF RELATED RATEMAKING PRINCIPLES AND TREATMENT. SOUTHWESTERN PUBLIC SERVICE COMPANY, APPLICANT. CASE NO UT DIRECT TESTIMONY MELISSA L. OSTROM on behalf SOUTHWESTERN PUBLIC SERVICE COMPANY

2 TABLE OF CONTENTS GLOSSARY OF ACRONYMS AND DEFINED TERMS... iii I. WITNESS IDENTIFICATION AND QUALIFICATIONS... II. ASSIGNMENT AND SUMMARY OF TESTIMONY AND RECOMMENDATIONS... III. REMAINING NET PLANT BALANCES... IV. RECOVERY OF REMAINING NET PLANT BALANCES... V. RECOVERY OF DECOMMISSIONING AND DISMANTLING COSTS... VI. CONCLUSION... VERIFICATION... ii

3 GLOSSARY OF ACRONYMS AND DEFINED TERMS Acronym/Defined Term Commission Meaning New Mexico Public Regulation Commission Cunningham Cunningham Generating Station Unit O&M Operation and Maintenance Plant X Plant X Generating Station Unit Plant X Plant X Generating Station Unit SPS Xcel Energy XES Southwestern Public Service Company, a New Mexico corporation Xcel Energy Inc. Xcel Energy Services Inc. iii

4 0 I. WITNESS IDENTIFICATION AND QUALIFICATIONS Q. Please state your name and business address. A. My name is. My business address is 0 Nicollet Mall, Minneapolis, Minnesota 0. Q. On whose behalf are you testifying in this proceeding? A. I am filing testimony on behalf Southwestern Public Service Company, a New Mexico corporation ( SPS and wholly-owned electric utility subsidiary Xcel Energy Inc. ( Xcel Energy. Q. By whom are you employed and in what position? A. I am employed by Xcel Energy Services Inc. ( XES, a wholly-owned subsidiary Xcel Energy, as Director Capital Asset Accounting. Q. Please briefly outline your responsibilities as Director Capital Asset Accounting. A. As Director Capital Asset Accounting, I am responsible for and oversee the overall capital asset accounting policies, the day-to-day maintenance accounting and tax records for capital assets, and the related reporting and regulatory requirements for Xcel Energy and its subsidiaries. Specifically, my duties include: establishing corporate capitalization policies for the development, enhancement, and maintenance the Corporate Continuing Property

5 0 0 Record process for all the plant assets Xcel Energy and its subsidiaries; managing the capital investment cost recovery process, which includes the development detailed actuarial analysis, regulatory filings with the various state and federal rate regulatory commissions, and expert testimony to support recovery levels in rate proceedings; directing the nuclear plant decommissioning funding process, which includes the development detailed engineering cost studies combined with a complete financial and economic analysis to develop detailed regulatory filings to establish the ratepayer funding levels necessary to accumulate the total future decommissioning cost requirement; overseeing the development corporate income tax deductions related to accelerated income tax depreciation expenses and providing for the computation and support deferred income taxes, which normalize the impact these accelerated deductions for ratemaking and book accounting purposes; assisting with the plant asset-related ratemaking process, which supports the rate filings for all the Xcel Energy Operating Companies retail and wholesale jurisdictions; and overseeing capital asset reporting and information processing necessary to disseminate capital asset information as required by various regulatory authorities (the Federal Energy Regulatory Commission, the Securities and Exchange Commission, and state commissions as well as meeting all internal information requirements necessary to sustain efficient and effective business operations. Q. Please describe your educational background. A. I obtained a Bachelor Business Administration degree with an Accounting Major from the University Wisconsin Madison in May 00. In May 00, I also

6 received a Master Accountancy degree from the University Wisconsin Madison. Q. Please describe your pressional experience. A. I began my pressional career with Deloitte & Touche, LLP in 00 as an Audit & Assurance Associate. In 00, I was promoted to Audit & Assurance Senior. In 00, I began working for XES as a Senior Accounting Analyst in the Sarbanes- Oxley Management Office, Corporate Accounting, and External Reporting departments. I held that position until 0, when I was promoted to Manager Budgeting and Forecasting for Energy Supply Finance. In 0, I began a position 0 as Manager, Capital Asset Accounting. assumed my current position. Q. Do you hold any pressional licenses? I held that position until 0, when I A. Yes. I currently hold an inactive license as a Certified Public Accountant in the State Minnesota. Q. Are you a member any pressional organizations? A. Yes. I am a member the Edison Electric Institute Property Accounting and Valuation Committee.

7 Q. Have you filed testimony before any regulatory authority? A. Yes. I submitted pre-filed testimony on SPS s behalf to the New Mexico Public Regulation Commission ( Commission regarding capital asset accounting, depreciation, and deferred tax issues in Case Nos. -00-UT and -00-UT. I have also submitted pre-filed testimony to the Public Utility Commission Texas on SPS s behalf on several occasions on the same issues. Finally, I have submitted pre-filed testimony to the Colorado Public Utilities Commission on behalf Public Service Company Colorado.

8 II. ASSIGNMENT AND SUMMARY OF TESTIMONY AND RECOMMENDATIONS 0 0 Q. What is your assignment in this proceeding? A. My testimony will discuss the following topics: the total plant investment in Plant X Generating Station Unit ( Plant X, Plant X Generating Station Unit ( Plant X, and Cunningham Generating Station Unit ( Cunningham ; the estimated costs to decommission those units and to dismantle parts them; the accumulated reserve collected through September 0, 0 for each unit; the expected accumulated reserve as the requested retirement date for each unit; and SPS s proposal that the Commission issue an order authorizing SPS to: ( record and recover the remaining, unrecovered net plant balance and estimated dismantling costs each unit at the time retirement and to include that amount in the base rates established in SPS s next base rate case; ( record in a deferred account the difference between actual and estimated decommissioning and dismantling costs for each the three units after completion actual dismantling activities; and ( after the three units are fully decommissioned and dismantled, either recover the deferred balance from customers if it is a regulatory asset, or return the balance to customers if it is a regulatory liability.

9 Q. Please summarize the conclusions and recommendations in your testimony. A. As the requested retirement date each unit, SPS projects the following unrecovered plant balance for each unit: Table MLO- Requested Retirement Date Total Company Amount New Mexico Retail Amount Cunningham December, 0 $,,0 $, Plant X December, 0 $, $, Plant X December, 00 $,0 $, 0 I recommend that the Commission authorize SPS to record and recover the unrecovered net plant balance each unit at the time retirement and to include that amount in the base rates established in the next SPS base rate case. As I will explain, the unrecovered net plant investment is far lower than the incremental capital costs and operation and maintenance ( O&M expense that SPS would incur if it were to continue operating those units past the retirement dates requested in SPS s application. The New Mexico retail amounts are based on the Coincident Peak-Production jurisdictional allocator approved in Case No. -00-UT.

10 I also recommend that the Commission allow SPS to record in a deferred account the difference between estimated and actual decommissioning and dismantling costs for Plant X, Plant X, and Cunningham. Finally, after the units have been fully decommissioned and dismantled, I recommend that the Commission allow SPS to recover the deferred balance from customers if it is a regulatory asset, or return the deferred balance to customers if it is a regulatory liability.

11 III. REMAINING NET PLANT BALANCES 0 Q. What is the purpose this section your testimony? A. In this section my testimony, I present the net unrecovered balance Cunningham, Plant X, and Plant X as September 0, 0, as well as the projected remaining balance for each unit at each unit s requested retirement date. Q. How did you calculate the net unrecovered plant balance as September 0, 0? A. I present the net unrecovered plant balance as September 0, 0, by unit, in Tables MLO-, MLO-, and MLO- below. Each table presents the total company amount and the New Mexico retail amount for each number presented. At a high level, the net unrecovered plant balance for each plant (Line No. each table is the total original plant investment (Line No. each table plus an estimated dismantling cost (Line No. each table minus the amount that SPS has recovered through depreciation expense (Line No. each table. Q. Has SPS fully recovered the original investments Cunningham, Plant X, or Plant X? A. No. As indicated in Line No. Tables MLO-, MLO-, and MLO-, as September 0, 0, SPS has a net unrecovered investment for each plant.

12 Q. Will SPS have fully recovered its investment in each unit at the requested retirement date? A. No. As shown in Line No. Tables MLO-, MLO-, and MLO-, additional depreciation expense will increase the Accumulated Depreciation Reserve Balance prior to actual plant retirement. This normal depreciation activity will reduce the unrecovered investment in each plant at its retirement, but as shown in Line No. in each the tables below, SPS anticipates that even after normal depreciation accruals, there will still be an unrecovered balance for each the plants. Table MLO-. Cunningham. Total Company New Mexico Retail. Plant Investment $,, $,,. Dismantling Cost Estimate $,, $,. Total to be Recovered $,,0 $,0,. Accumulated Depreciation Reserve Balance as September 0, 0. Net Unrecovered Plant Balance as September 0, 0. Estimated Incremental Accumulated Depreciation Reserve Balance through December, 0. Expected Net Unrecovered Plant Balance at December, 0 $,0, $,, $,, $, $, $, $,,0 $,

13 Table MLO-. Plant X. Total Company New Mexico Retail. Plant Investment $,, $,,0. Dismantling Cost Estimate $,, $,. Total to be Recovered $,, $,,0. Accumulated Depreciation Reserve Balance as September 0, 0 $,0,0 $,,. Net Unrecovered Plant Balance as September 0, 0 $, $,. Estimated Incremental Accumulated Depreciation Reserve Balance through December, $, $, 0. Expected Net Unrecovered Plant Balance at December, 0 $, $, Table MLO-. Plant X. Total Company New Mexico Retail. Plant Investment $,0, $,,00. Dismantling Cost Estimate $,,0 $,0. Total to be Recovered $,0, $,,. Accumulated Depreciation Reserve Balance as September 0, 0 $,, $,,. Net Unrecovered Plant Balance as September 0, 0 $,0 $,0. Estimated Incremental Accumulated Depreciation Reserve Balance through December, $ 0, $,0 00. Expected Net Unrecovered Plant Balance at December, 00 $,0 $, 0

14 0 Q. Why does SPS collect depreciation expense? A. Depreciation rates are established to recover the original cost an investment as well as eventual dismantling costs over an investment s estimated useful life. The objective computing depreciation is to help ensure that those customers who benefit from the use the asset while it is in service pay their pro rata share for the investment, including dismantling costs. Q. In what case did the Commission approve SPS s current depreciation rates and dismantling estimates? A. SPS s current depreciation rates, including dismantling estimates incorporated into the net salvage percentages used in the currently approved depreciation rates, were presented and accepted by the Commission in Case No UT. The parties agreed to maintain those depreciation rates as part the settlement Case No. -00-UT, which the Commission approved. Those same depreciation rates In the Matter Southwestern Public Service Company s Application for Revision Its Retail Electric Rates Under Advice Notice No., Case No UT, Recommended Decision at (Jan., 0 (approving service lives proposed by SPS and Final Order Partially Adopting Recommended Decision (Mar., 0. See In the Matter Southwestern Public Service Company s Application for Revision Its Retail Electric Rates Under Advice Notice No., Case No. -00-UT, Certification Stipulation at (Jul., 0 and Final Order Adopting Certification Stipulation with Modification (Aug. 0, 0.

15 were maintained by the final order issued in Case No. -00-UT, SPS s most recently completed base rate case. Q. Why will there be unrecovered balances at a plant s expected retirement? A. In general, it is typical to have some amount unrecovered plant balance at a plant s expected retirement date due to the way depreciation rates are calculated. The depreciation rate is calculated based on a net plant value divided by the remaining life at a point in time. Any plant additions that occur after the 0 depreciation rate is set will increase the net plant value remaining to be recovered and therefore the established rate will no longer be sufficient to ensure full recovery by the end the expected remaining life. Accordingly, there will likely be some unrecovered plant amount at the time retirement because the depreciation rates were not calculated to include that additional investment. Similarly, any change to the expected remaining life from that used to establish the depreciation rates will also result in either an under- or over-recovery the plant amount if the retirement date is earlier or later than previously expected. See In the Matter Southwester Public Service Company s Application for Revision Its Retail Rates Under Advice Notice No., Case No. -00-UT, Recommended Decision at (Jun., 0 and Final Order Adopting Recommended Decision with Modification at (Sep., 0.

16 IV. RECOVERY OF REMAINING NET PLANT BALANCES 0 Q. In this filing, is SPS requesting recovery the remaining unrecovered investment relating to Plant X, Plant X, or Cunningham? A. Yes. In this case, SPS seeks a Commission order authorizing recovery the remaining net plant balance each unit as the date that unit s retirement. Then, in the New Mexico base rate case that SPS plans to file in 0, SPS will seek Commission approval to include in base rates the amount unrecovered net plant investment approved in this case for those three units. Q. How does the unrecovered net plant balance for each unit compare to the incremental capital and O&M costs that SPS would incur if the plants were to remain in operation past the retirement dates proposed by SPS? A. SPS witness Randy J. Larson s direct testimony quantifies the incremental capital and O&M costs that would be necessary to continue operating the three units beyond the dates proposed by SPS for retirement those units. My Table MLO- compares the difference between the capital and O&M costs quantified by Mr. Larson and the unrecovered net plant balance each unit.

17 Table MLO- Unit Unrecovered Net Plant Investment at Retirement Date (New Mexico Retail Incremental Capital and O&M Costs (New Mexico Retail Cunningham $, $,, Plant X $, $,000 Plant X $, $,,000 As Table MLO- demonstrates, the unrecovered net plant investment is far lower than the incremental capital and O&M costs that would be necessary to continue operating Cunninghman, Plant X, and Plant X through 0. This amount is composed $,000 that would be incurred for ordinary-course--business O&M costs, the $,,0 capital costs identified in Mr. Larson s Table RJL- for the overhaul Cunningham, and the $,00 incremental O&M costs identified in his Table RJL- for the overhaul Cunningham. This amount is composed $,000 ordinary-course--business O&M, $,000 capital costs for the 00 overhaul, and $,000 O&M costs associated with the 00 overhaul. This amount is conservative because it does not include the additional capital expenditures for cooling tower drift eliminators and pressure relief valves, nor does it include amounts for subsequent maintenance overhauls. Please refer to pages - Mr. Larson s testimony. This amount is composed $,000 ordinary-course--business O&M, $,00,000 capital costs for the 00 overhaul, and $,000 O&M costs associated with the 00 overhaul. This amount is conservative because it does not include the additional capital expenditures for cooling tower drift eliminators and pressure relief valves, nor doeds it include amounts for subsequent maintenance overhauls. Please refer to pages - Mr. Larson s testimony.

18 0 V. RECOVERY OF DECOMMISSIONING AND DISMANTLING COSTS Q. What do you discuss in this section your testimony? A. In this section, I describe SPS s request with respect to the recovery decommissioning and dismantling costs associated with Plant X, Plant X, and Cunningham. Q. Do SPS s current depreciation rates include any amounts that are intended to recover decommissioning and dismantling costs? A. Yes. The depreciation rates established by the Commission in prior cases have included a provision for estimated decommissioning and dismantling costs. However, the actual decommissioning and dismantling costs may be higher or lower than the estimated costs. Q. Is SPS proposing to completely dismantle Plant X, Plant X, and Cunningham as soon as they are decommissioned? A. No. As Mr. Larson explains in his testimony, even if the Commission authorizes those three units to be retired on the dates requested in the application, the remaining units at the Plant X Generating Station and Cunningham Generating Station will continue to operate for several more years. Because it is more efficient to dismantle all the units at one time than to dismantle them piecemeal, Plant X, Plant X, and Cunningham will not be dismantled for several years.

19 Q. What is SPS requesting in this case with respect to the decommissioning and dismantling costs? A. SPS requests that the Commission allow SPS to record in a deferred account the difference between the estimated decommissioning and dismantling costs and the actual decommissioning and dismantling costs. In a proceeding that occurs after all the Plant X Generating Station and Cunningham Station units are dismantled, SPS will ask for recovery the amount from customers if it is a regulatory asset or will ask for permission to credit the amount to customers if it is a regulatory liability.

20 VI. CONCLUSION 0 0 Q. Please summarize the relief that SPS seeks in this case with respect to the remaining plant investment and the decommissioning and dismantling costs. A. SPS requests that the Commission issue a final order authorizing SPS to: ( record and recover the remaining, unrecovered net plant balance each unit at the time retirement and to include that amount in the base rates established in SPS s next base rate case; ( record in a deferred account the difference between actual and estimated decommissioning and dismantling costs for each the three units; and ( after the three units are fully decommissioned and dismantled, either recover the deferred balance from customers if it is a regulatory asset, or return the balance to customers if it is a regulatory liability. Q. Is SPS asking the Commission to issue a final order in this case by any particular time? A. Yes. SPS respectfully requests that the Commission issue a final order in this case no later than April, 0. SPS is planning to file a base rate case in New Mexico in summer 0, and as part that rate case SPS will present a new depreciation study. If Plant X and Cunningham remain in service beyond the end 0, and Plant X remains in service beyond 00, SPS will need to request depreciation rates for them as part the depreciation study. On the other hand, if Plant X and Cunningham are to be retired at the end 0 and Plant X at

21 the end 00, new rates need not be requested in the depreciation study, and the Commission need not address the issue proper depreciation rates for them. Q. Does this conclude your pre-filed direct testimony? A. Yes.

BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) SUPPLEMENTAL DIRECT TESTIMONY MELISSA L. OSTROM.

BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION IN THE MATTER OF SOUTHWESTERN PUBLIC SERVICE COMPANY S APPLICATION REQUESTING APPROVAL TO RETIRE AND ABANDON ITS PLANT X GENERATING STATION UNIT, PLANT