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1 Commission/Docket Type of Proceeding Testimony FERC ER08-313E SPS Wholesale Transmission Rebuttal Testimony Formula ER PSCO Wholesale Production Direct Testimony Formula ER PSCO Wholesale Production Direct Testimony Formula MPUC E002/GR Electric Rate Case Direct and Rebuttal Testimony E002/GR Electric Rate Case Direct and Rebuttal Testimony E002/E002/GR Electric Rate Case Direct Testimony Commission Docket No Electric Rate Case Direct and Rebuttal Testimony Docket No Electric Rate Case Direct and Rebuttal Testimony Docket No Transmission Cost Recovery Rebuttal Testimony Factor ("TCRF") Docket No Electric Rate Case Direct Testimony Docket No Electric Rate Case Direct Testimony Docket No Asset Sale Direct Testimony Docket No TCRF Direct Testimony NMPRC UT Electric Rate Case Direct and Rebuttal Testimony UT Asset Sale Direct Testimony (in lieu of witness Savage) NDPSC PU and Asset Sale Direct and Rebuttal Testimony PU PU Electric Rate Case Rebuttal Testimony PU Gas Rate Case Rebuttal Testimony PSCW 4220-UR-117 Electric and Gas Rate Case Rebuttal Testimony Perkett Direct - Revenue Requirement Page 10 RRl of

2 1 II. ASSIGNMENT AND SUMMARY OF TESTIMONY AND 2 RECOMMENDATIONS 3 Q. What is your assignment in this proceeding? 4 A. I will address two areas in this proceeding: book depreciation and capital additions. 5 Regarding book depreciation, I will introduce the witness that discusses SPS's 6 Depreciation Study ("Depreciation Study") and I will discuss the following topics: 7 SPS's Depreciation Study with the resulting depreciation expense; 8 SPS's proposed dismantling cost true-up; and 9 SPS's development of the balance of accumulated depreciation for the 10 Texas retail jurisdiction and the related balance of accumulated deferred 11 federal income taxes (the unblending adjustment). 12 Regarding SPS's capital additions, I will discuss the inclusion of affiliate 13 charges in capital additions made to plant-in-service during the period July 1, 2012 to 14 June 30, In addition, I will discuss the prudence of production plant capital 15 additions over $20 million closed to plant-in-service before January 1, I 16 provide a summary of those additions in Attachment LHP-RR- 10. I also introduce 17 the other witnesses who will discuss SPS capital additions. 18 In addition to these areas, I sponsor or co-sponsor the following Schedules in 19 SPS's Rate Filing Package ("RFP"): C-1, C-2, C-3, C-4.1, C-5, D, D-1, D-2, D-3, 20 D-4, D-5, D-6, D-7, D-8, G-7.2, G-7.4a G-7-4b, G-7.4c, G-7.5, G-7.5a, G-7.5b, 21 G-7.5c, G-7-5d, G-7.5e, G-7.7, G-7.13, G-7.13c, and H-5.1. Perkett Direct - Revenue Requirement Page 11 RRl of

3 1 Q. Please summarize your testimony and the recommendations you present 2 regarding book depreciation and capital additions. 3 A. My testimony and the included recommendations can be summarized as follows: 4 SPS requests approval of new depreciation rates, updates to asset lives, 5 and the associated depreciation expense. SPS's requested increase of 6 $32,552,262 (total SPS before jurisdictional allocations, or "total 7 company") to its depreciation and amortization expense is reasonable and 8 necessary. SPS requests the new depreciation rates become effective 9 when the final rates in this docket become effective. 10 SPS has made an adjustment to restate its Texas retail depreciation 11 reserve and accumulated deferred federal income tax ("ADF1T") to reflect 12 the Commission's authorized depreciation rates (the unblending 13 adjustment). SPS's proposed adjustment to decrease the financial 14 depreciation and amortization reserve by $118,342,818 (total company) is 15 reasonable and reflects the continued acceptance of an annual, routine 16 adjustment to unblend the depreciation reserve. The ADFIT was 17 increased by $36,503,287 to reflect the impact that the Texas-only 18 depreciation rates have on ADFIT. 19 SPS requests approval of $385,658,781 (total company) in capital 20 additions closed to plant-in-service for the period from July 1, 2012 to 21 June 30, 2013, and the associated capitalized affiliate charges of 22 $17,855,796 (total company). These proposed capital additions are 23 reasonable and necessary, and support SPS's ability to provide electric 24 service to its customers. 25 SPS's capital additions of $3,617,338,609 (total company), closed to 26 plant-in-service between January 1, 1978 and December 31, 2009, are 27 reasonable and necessary, and support SPS's ability to provide electric 28 service to its customers. 29 SPS has reclassified approximately $8,535 (total company) of land to 30 non-utility property and removed that amount from Plant Held for Future 31 Use ("PHFU"). Perkett Direct - Revenue Requirement Page 12 RR1-523 of

4 1 III. DEPRECIATION ISSUES 2 Q. What topics do you address in this section of your testimony? 3 A. In this section of my testimony, I will discuss SPS's Depreciation Study, the net 4 salvage rates for Production Plant, SPS's proposed dismantling cost true-up, and the 5 Texas-specific balance of SPS's accumulated depreciation. 6 A. Depreciation Study 7 Q. Why has SPS presented a Depreciation Study in this proceeding? 8 A. In this rate case, SPS is presenting a Depreciation Study because the current 9 depreciation rates were last revised with SPS's 2008 general rate case, Docket No A Depreciation Study also is being submitted because certain of SPS's asset 11 lives require adjustments, and the currently approved net salvage rates are based on 12 an unrealistic assumption that scrap value will exceed dismantling costs. 13 Q. In the previous section of your testimony, you referred to a Depreciation Study. 14 Who performed the Depreciation Study? 15 A. A Depreciation Study was performed at my direction and under my supervision. SPS 16 hired the Alliance Consulting Group ("Alliance") to prepare a Depreciation Study. 17 Alliance personnel have over 50 years of combined experience in conducting 18 depreciation studies, as well as many years of utility experience managing and 19 studying utility assets. The 2012 Depreciation Study produced by Alliance is 2 Application of Southwestern Public Service Company for Authority to Change Rates, to Reconcile Fuel and Purchased Power Costs for 2006 and 2007 and to Provide a Credit for Fuel Cost Savings, Docket No (Jun. 2, 2009). Perkett Direct - Revenue Requirement Page 13 RR1-524 of

5 1 provided as Attachment DAW-RR-1 to the direct testimony of SPS witness Dane A. 2 Watson. A summary of the Alliance depreciation rate comparison is included in 3 Attachment DAW-RR-1, Appendix B. 4 Q. What net salvage rates were used in the Depreciation Study? 5 A. For Steam Production Plant and Other Production Plant, Alliance used a negative 5% 6 net salvage rate. These net salvage rates as well as those used for Transmission, 7 Distribution and General Plant are included in Appendix C of the Depreciation Study 8 provided as Attachment DAW-RR-1 to Mr. Watson's direct testimony. 9 Q. Please explain why the current net salvage rates have unrealistically low 10 dismantling costs. 11 A. The current net salvage rates were set in the settlement in SPS's 2008 general rate 12 case in Docket No , and have remained unchanged in last two rate case 13 settlements in Docket Nos and The current rates are not based on 14 any detailed engineering dismantling cost study. The dismantling study presented by 15 SPS in Docket No shows that removal costs are expected to be significantly 16 higher than amounts currently recovered under existing net salvage rates. 3 Application of Southwestern Public Service Company for Authority to Change Rates and to Reconcile Fuel and Purchased Power Costs for 2008 and 2009, Docket No (Mar. 25, 2011). 4 Application of Southwestern Public Service Company for Authority to Change Rates and to Reconcile Fuel and Purchased Power Costs for the Period January 1, 2010 through June 30, 2012, Docket No (Jun. 19, 2013). Perkett Direct - Revenue Requirement Page 14 RR1-525 of

6 I Q. Does the Depreciation Study reflect any changes in the retirement dates used for 2 calculating the remaining life for generation units? 3 A. Yes. Specifically, the Depreciation Study proposes an extension of the Cunningham 4 Unit 1 service life by eight years, a reduction of the Moore County service life by one 5 year, an extension of the Nichols Unit 2 service life by one year, an extension of 6 Plant X Units 1 and 2 service lives by five years, and an extension of Plant X Unit 3 7 service life by one year. The study also proposes an extension of Jones Units 8 common facilities to the year 2058 to coincide with the life of Jones Unit 4. Finally, 9 the end of life date for Riverview has been revised to 2013 to reflect the actual 10 retirement date. 11 Q. Are there any outstanding issues related to the settlement in SPS's 2012 rate 12 case in Docket No ? 13 A. Yes. The Stipulation Agreement in Docket No stated that "SPS shall fully 14 justify the continued use of the assumed underlying amortization period reflected in 15 the vintage group accounting in all future rate cases for each account." This 16 requirement was not changed in the last two settlements in Docket Nos and SPS requests to include an analysis of the lives and net salvage rates for those 18 assets using vintage group accounting in each depreciation study rather than with 19 each rate proceeding. In some of the most recently fully litigated cases regarding 20 depreciation, the Commission approved vintage group amortization for Oncor 21 Electric Delivery Company, LLC (Docket No ), CenterPoint Energy Houston Perkett Direct - Revenue Requirement Page 15 RR1-526 of

7 1 Electric LLC (Docket No ), and Entergy Corp. (Docket No ). SPS also 2 requests that no further justification of AR- 15 depreciation parameters be required in 3 future proceedings. In the above mentioned cases, the Commission determined that 4 no further justification of depreciation parameters is required in future proceedings 5 for those companies. 6 B. Results of Depreciation Study 7 Q. Please describe the Depreciation Study. 8 A. The Depreciation Study is an analysis of annual depreciation for SPS based on SPS's 9 depreciable plant-in-service as of June 30, The Depreciation Study 10 recommends new depreciation rates for Production Plant, Other Production Plant, 11 Transmission Plant, Distribution Plant, and General Plant based on average life 12 calculations and net salvage rates. 13 Q. What does SPS propose based on the results of the Depreciation Study? 14 A. Based on the Depreciation Study recommendations, SPS proposes depreciation rates 15 as provided in Attachment LHP-RR Q. What is the effect of SPS's newly proposed depreciation rates? 17 A. The estimated impact of these adjustments on the Test Year ("Test Year") 18 depreciation accruals is an increase of $32,504,037 on a total company basis. There 19 is also a change in proposed amortization rates that net to an increase of $48, (total company). The following table shows the functional detail of the requested 21 depreciation increase. Perkett Direct - Revenue Requirement Page 16 RRl of

8 1 Table LHP-RR-2 Depreciation Expense Change Total Company Steam Production $22,116,833 Other Production $864,743 Transmission $270,191 Distribution $912,740 General $8,339,530 Total Increase $32,504,037 2 Q. What is the proposed effective date for these changes? 3 A. SPS requests that these changes be made effective when final general rates become 4 effective in this docket. A worksheet summarizing the current authorized rates as 5 compared to the proposed rates has been provided in Mr. Watson's Attachment 6 DAW-RR-1 as well as in Attachment LHP-RR-3. The proposed depreciation rates 7 are incorporated into the cost of service study performed by SPS witness Kathy 8 McNulty Kropp. 9 Q. Does the Depreciation Study address any initial depreciation rates for an asset? 10 A. Yes. The Blackhawk gas pipeline is owned by SPS and supplies fuel to the 11 Blackhawk Station cogeneration facility, which is owned by Borger Energy 12 Associates. SPS does not own Blackhawk Station, but does purchase power from the 13 facility under a Power Purchase Agreement. The asset has been fully depreciated 14 with a zero net book value since the ownership of the pipeline was transferred to 15 SPS. It was assumed that SPS paid for the initial investment in the pipeline through Perkett Direct - Revenue Requirement Page 17 RR1-528 of

9 1 the Power Purchase Agreement, thus the initial investment was already recovered 2 from customers when the title transfer occurred. Due to gas pipeline safety 3 legislation, SPS was recently required to perform safety and integrity work, including 4 capital additions of approximately $1.3 million during the Test Year. Because SPS 5 has not previously recorded depreciation expense on the asset, it is requesting 6 approval of a depreciation rate with a life based on the current Power Purchase 7 Agreement. SPS is requesting a depreciation rate of %. 8 C. Net Salvage Rates for Production Plant 9 Q. Did SPS have a new dismantling cost study performed for the technical update 10 to the Depreciation Study? 11 A. No. Alliance relied on the dismantling cost study that TLG Services conducted for 12 the last SPS rate case, Docket No , to verify that the use of -5% net salvage is 13 appropriate. The study is provided as part of Attachment DAW-RR-3 to Mr. 14 Watson's testimony. 15 Q. What were the results of the dismantling cost study filed in Docket No ? 16 A. The study estimates that the dismantling and demolition of the 27 units in SPS's 17 fossil-fuel fleet will cost $131 million, including credit for scrap generated and sold 18 in the dismantling process. Perkett Direct - Revenue Requirement Page 18 RR1-529 of

10 1 Q. How are the results of the dismantling cost study used in the Depreciation 2 Study? 3 A. As further discussed by Mr. Watson, the Depreciation Study proposes -5% net 4 salvage rates for Production and Other Production plant to determine depreciation 5 rates. The dismantling cost study is used in the Depreciation Study to ensure the 6 reasonableness of proposed net salvage rates. 7 D. Developing a Texas-Specific Balance of Accumulated Depreciation 8 Q. What is the relationship between depreciation rates and the balance of 9 accumulated depreciation? 10 A. The higher the depreciation rate, the faster the balance of accumulated depreciation 11 grows. (Accumulated depreciation is also referred to as the depreciation reserve.) 12 Thus, if the depreciation rate for an asset is, say, 4%, there will be more accumulated 13 depreciation over time than if the depreciation rate were 2.5%. 14 Q. Are all jurisdictions required to set the same depreciation rates? 15 A. No. Each jurisdiction sets its own depreciation rates for assets or classes of assets. 16 Thus, a utility operating in several jurisdictions, as SPS does, can have a different 17 depreciation rate in each jurisdiction for the same asset. Consequently, the 18 accumulated depreciation balance will be different in each jurisdiction. 19 Q. Please explain what you mean by a "blended" depreciation reserve? 20 A. The financial depreciation reserve shown on SPS's financial books is a blend of all of 21 the jurisdictional depreciation rates weighted by the jurisdictional allocators for the Perkett Direct - Revenue Requirement Page 19 RR1-530 of

11 1 applicable time period. Suppose, for example, that SPS had the following 2 depreciation rates and jurisdictional allocators for a particular FERC account during 3 the period in question: 4 Table LHP-RR-3 Sample Calculation of Blended Depreciation Rate Jurisdiction Jurisdictional Depreciation Rate Jurisdictional Allocator Blended Depreciation Rate Texas Retail % 44.3% % FERC Wholesale % 40.6% % New Mexico Retail % 15.1% % Blended Financial % 5 In this example, the blended depreciation rate for this period would be %. 6 Q. Using the example in Table LHP-3, should rates be set using the % 7 blended jurisdictional allocator for this FERC account? 8 A. No. Although blending is necessary to derive a single depreciation reserve number 9 for financial reporting purposes, using that number for ratemaking purposes would 10 give jurisdictions with low depreciation rates credit for more depreciation than 11 customers in those jurisdictions have provided for through rates. Conversely, it 12 would give customers in jurisdictions with high depreciation rates credit for less 13 depreciation than they have provided for through rates. In the particular example set 14 forth in Table LHP-RR-3, using the reserve amount calculated using a blended 15 depreciation rate would give Texas and New Mexico retail customers credit for more Perkett Direct - Revenue Requirement Page 20 RR1-531 of

12 depreciation than they have provided for in prior rates, and it would give FERC 2 customers credit for less depreciation than they have provided for in prior rates. And 3 because the depreciation reserve is an offset to rate base, using a blended depreciation 4 reserve would cause the Texas and New Mexico rate bases to be too low and the FERC rate base to be too high. 6 Q. How can the utility avoid giving too much or too little depreciation credit to the 7 various jurisdictions for ratemaking purposes? A. The utility can avoid that problem by unblending the financial depreciation reserve to 9 reflect each jurisdiction's depreciation reserve. That is what SPS has done in this 10 case. 11 Q. Is this a new approach to determining the depreciation reserve in a rate case? 12 A. No. SPS used this approach to determine its proposed accumulated depreciation in 13 its last four base rate cases: Docket Nos , , 38147, and Further, 14 the NMPRC also has approved the unblending of SPS's accumulated depreciation,6 15 and FERC has directed SPS to use this approach in wholesale rate cases. ' Application of Southwestern Public Service Company forauthority to Change Rates; Reconciliation of its Fuel Costs for 2004 and 2005; Authority to Revise the Semi Annual Formulae Originally Approved in Docket No Used to Adjust its Fuel Factors; and Related Relief, Docket No (Jul. 27, 2007). 6 In the Matter of Southwestern Public Service Company's Application for Revision of Its Retail Electric Rates Pursuant to Advice Notice Nos. 208 and 209 and All Associated Approvals, Case No UT (Aug. 26, 2008). Perkett Direct - Revenue Requirement Page 21 RR1-532 of

13 1 Q. Please explain how SPS unblended the financial depreciation reserve to achieve 2 a Texas-only depreciation reserve. 3 A. SPS started with the financial depreciation reserve and calculated an adjustment to 4 produce a depreciation reserve, at a total company level, assuming all three 5 jurisdictions used the Commission-approved depreciation rates. In other words, SPS 6 recalculated what the total company depreciation reserve would be if all three 7 jurisdictions always used the same depreciation rates as set by the Commission. The 8 adjustment decreased the financial depreciation reserve by $118,342,818. Given that 9 this adjustment resulted in a total company depreciation reserve, the standard 10 jurisdictional allocation on rate base could be performed to arrive at the proper return 11 on rate base. The details of the calculation are provided as Attachment LHP-RR I refer to my adjustment as unblending the depreciation reserve, in the sense 13 that I have taken the financial depreciation reserve (i.e., the depreciation reserve 14 shown on SPS's financial books), which reflects a blend of the depreciation rates 15 from SPS's three jurisdictions, and have adjusted, or restated, the balance to be a 16 total company depreciation reserve as if all three jurisdictions had used the 17 depreciation rates approved by the Commission. The method that SPS uses assures 18 that the accumulated financial reserve is fully assigned among the three jurisdictions. Perkett Direct - Revenue Requirement Page 22 RRI of

14 1 Q. Is there a deferred tax adjustment associated with the depreciation unblending 2 adjustment? 3 A. Yes. The ADFIT is for the most part a timing difference between the recognition of 4 tax depreciation on an asset versus the recognition of book depreciation on that same 5 asset. The entire asset cost is depreciated either for taxes or books differing only for 6 the life and the method. Tax depreciation uses lives prescribed by the Internal 7 Revenue Service, which are usually shorter than lives approved for book 8 depreciation. Tax depreciation uses the accelerated recovery methods, such as sum- 9 of-the-year-digits or double-declining-balance method, while the book depreciation 10 calculation is based on the straight-line method. ADFIT generally is the difference 11 between the net plant for book purposes less and the net plant for tax purposes. 12 Therefore, a change to the depreciation reserve to unblend would affect net plant 13 (original plant cost less depreciation reserve) for the books and subsequently affect 14 the ADFIT. 15 However, the depreciation reserve adjustment discussed earlier relates to 16 assets that were installed and depreciated over many years. When an asset is placed 17 in-service, it maintains the year of installation in the tax records and, in turn, the asset 18 is linked to the tax rules in effect for that year. These in-service years are known as 19 tax vintages. SPS has tax vintages spanning back to As deferred tax rules 20 changed throughout time, the calculation of the adjustment using only the rules in 21 effect today would ignore all the rules still applicable to earlier vintages. Thus, it is Perkett Direct - Revenue Requirement Page 23 RR1-534 of

15 1 not nearly as simple as taking the accumulated depreciation adjustment times the 2 current federal tax rate. 3 In addition, adjustments to ADFIT in rate base that do not reflect the amounts 4 on SPS's books could be perceived as not complying with the normalization 5 requirements of the Internal Revenue Code. As such, it is inaccurate to use a simple 6 calculation to unblend the ADFIT portion of rate base. 7 In its last three rate cases, SPS has used a method to unblend the ADFIT that 8 was designed to greatly minimize any potential normalization violation. The 9 financial ADFIT is the appropriate balance based on the Internal Revenue Service 10 normalization rules. That said, the ADFIT that is on the financial books should be 11 fully allocated to each jurisdiction to avoid having an over-provision or 12 under-provision of deferred taxes over the lives of the assets. 13 Attachment LHP-RR-9 contains the detailed calculations. The calculation 14 begins with the total company figures for net tax and net book as of June 30, Each jurisdiction is run parallel to the total company with the unblending 16 accumulated depreciation adjustment affecting each jurisdiction's net book amount. 17 Q. Is this the same methodology that SPS filed in its most recent rate case? 18 A. Yes. I used the same methodology that SPS filed in Docket No and, in this 19 current case, applied it to the June 2013 ADFIT balance. Perkett Direct - Revenue Requirement Page 24 RR1-535 of

16 1 Q. What is the dollar amount of your adjustment? 2 A. The jurisdictional ADFIT calculated with the unblended accumulated depreciation 3 adjustment results in a $698,484,055 liability balance (total company) using Texas 4 only depreciation rates as compared to a $661,980,768 financial liability balance 5 (total company), using the blended financial depreciation rates. Thus, the unblended 6 ADF1T adjustment is $36,503,287 for the Texas-only depreciation rates (total 7 company) at a 35% tax rate. See Attachment LHP-RR-9. 8 Q. What method of calculating accumulated deferred income tax balances has SPS 9 used? 10 A. For income tax determinations, SPS uses accelerated methods to calculate its tax 11 depreciation as defined by current tax laws and regulations. The current method used 12 to calculate federal tax depreciation deductions is the Modified Accelerated Cost 13 Recovery System ("MACRS"). At various times, Congress has enacted laws to spur 14 investment that have allowed for further acceleration beyond the MACRS method. 15 The various laws enacted have allowed for 30%, 50%, and now even 100% of the tax 16 asset to be depreciated in the first year, with the remaining investment following the 17 MACRS method (at least for the 30% and 50% accelerations). This additional 18 acceleration over the MACRS method is referred to as bonus depreciation. Perkett Direct - Revenue Requirement Page 25 RR1-536 of

17 Q. Does SPS follow the tax laws enacted since 2009 that contain a provision for 2 allowing for bonus depreciation? A. Yes. The effects of these laws have been calculated and incorporated into the data 4 used in developing the revenue requirements in this case. Basically, the allowance of 5 bonus depreciation increases the ADFIT balance. An increase in this balance causes 6 a decrease in plant-related rate base. Perkett Direct - Revenue Requirement Page 26 RR1-537 of

18 I IV. CAPITAL ADDITIONS 2 Q. What topic do you discuss in this section of your testimony? 3 A. In this section of my testimony, I discuss SPS's request to include in rate base its 4 capital additions made to plant-in-service during the period July 1, 2012 through June 5 30, July 2012 is the first month after the end of the test year in SPS's last base 6 rate case, Docket No June 30, 2013 is the end of the Test Year in this current 7 rate case. I also will discuss the prudence of capital additions included in SPS's rate 8 base as of the end of the Test Year that were closed to plant-in-service during the 9 period January 1, 1978 through December 31, January 1978 is the first month 10 after the end of the test year in SPS's last fully litigated rate case (i.e., the revenue 11 requirement was not established through a settlement), Docket No December 12 31, 2009 is the end of the test year in Docket No Q. What is the amount of SPS's requested capital additions for the period July through June 2013? 15 A. Total capital additions to plant-in-service for the period July 1, 2012 through June 30, are $385,658,781 (total company). 17 Q. Are there any affiliate charges included in SPS's requested capital additions for 18 the period July 2012 through June 2013? 19 A. Yes. The affiliate charges within the requested capital additions are $17,855, (total company). In regard to those affiliate charges, I will: (1) demonstrate that ' Application of Southwestern Public Service Company for a Rate Increase, Docket No (Oct. 2, 1978). The test year was calendar year Perkett Direct - Revenue Requirement Page 27 RR1-538 of

19 1 these costs are appropriate construction charges; (2) validate that "direct" charge in 2 fact means just that; and (3) establish that SPS was charged equitably for the work 3 received. 4 My discussion will divide the affiliate charges into two segments, Software 5 and All Other Plant. It is appropriate to split the charges in this manner because the 6 charges for capitalized software are mostly assigned to SPS through an allocation. 7 Though allocated, these costs are still appropriately included in rate base, but the 8 equitable nature of this assignment method will be described separately from the 9 direct charge method generally used for other construction costs. 10 Q. Have you prepared a list of SPS's requested capital additions? 11 A. Yes. My Attachment LHP-RR-1 is a list of SPS's requested capital additions. This 12 attachment provides the following information: Column A - Work Order Number Provides the Work Order number for the project Column B - Work Order Provides a short title for the work Description order. Column C - Column D - Asset Class Witness Identifies the type of asset. Identifies the witness supporting the project. Column E - Parent Provides the parent work order number for the project Column F - Parent Description Provides a short title for the parent work order Perkett Direct - Revenue Requirement Page 28 RR1-539 of

20 Column G - In-Service Date Column H - Addition to Plant-in- Service (July June 2013) Date that the project was completed and added to plant-in-service. The total company dollar amount of the addition to plant-in-service for the project. Column I - XES Charges The amount of charges from XES that (Included in Column are included in the total company dollar H) amount of addition to plant-in-service for the project in Column H. Column J Other Affiliate The amount of charges from affiliates Charges (Included in other than XES that are included in the Column H) total company dollar amount of addition to plant-in-service for the project in Column H. Column K - Total Affiliate Total of Columns I and J associated Charges (Included in with new plant-in-service shown in Column H) Column H. Column L - Total Native Charges (Columns H less K) Within the Total Additions to Plant-in- Service Shown in Column (H) The dollar amount (total company) of the addition to plant in service in Column H that is not an affiliate charge. 1 Q. 2 A Are you the only SPS witness who discusses capital additions? No. I discuss the accounting practices applicable to capital, including overhead pools applied to capital projects and affiliate charges. The following five SPS witnesses support the reasonableness and necessity of the specific capital projects within the requested capital additions: John S. Fulton - transmission and related general plant. Perkett Direct - Revenue Requirement Page 29 RRI of

21 Alan J. Davidson David C. Harkness Danny A. Nygaard Kelly A. Bloch - production and related general plant. - general plant (related to information technology) and software. - general plant (related to facilities and property services). - distribution and related general plant. These witnesses are involved in the analysis and review that their respective 2 business areas perform to assure the capital expenditures are crucial and necessary to 3 support their areas. I am responsible for the calculations of plant-related balances 4 and expenses, which can be derived only after the indicated business areas have 5 completed their analyses. The process of moving the costs from Construction Work 6 In Progress ("CWIP") to plant produces the capital additions that then form the basis 7 from which all the other plant-related information can be provided. 8 A. Plant Additions 9 Q. What part of construction cost is included in rate base? 10 A. 11 None of SPS's CWIP is included in rate base until the asset is fully constructed and closed to plant-in-service. The asset must be used and useful before the end of the 12 Test Year, June 30, 2013, to be included in rate base. Most of SPS's assets are 13 self-constructed and thus SPS has a robust construction program. When an asset becomes used and useful, the accumulation of construction charges is closed to plant-in-service, FERC Account 106, Construction Completed Not Classified (a Perkett Direct - Revenue Requirement Page 30 RR1-541 of

22 1 holding account once the asset is in use but has not yet been allocated to the 2 individual retirement units constructed), and then to FERC Account 101, Electric 3 Plant in Service (the account where the asset is transferred once it is allocated to 4 retirement units). Therefore, an asset in its construction phase is not included in rate 5 base until it is closed from construction and recognized as a plant addition. As I 6 mentioned earlier, my Attachment LHP-RR-1 lists all capital additions for the period 7 July 1, 2012 through June 30, Q. Please describe the significance of the in-service date as it appears in Column G 9 on the individual witness tabs of Attachment LHP-RR A. The in-service date is the date upon which the asset is in use. When the asset is 11 moved to plant-in-service, the utility stops accruing Allowance for Funds Used 12 During Construction and begins accruing book depreciation. Some capital work 13 involves multiple assets being constructed in the same work order with many 14 in-service dates (commonly referred to as "blanket" work orders). On Attachment 15 LHP-RR-1, Column E, blanket work orders have an in-service date of "various." 16 Typically, charges can continue for a short period after the in-service date is 17 recognized on a work order. These charges are for recognition of the final bills from 18 vendors, testing of the equipment, restoration of the ground, settlement of any 19 disputes, and returning unused stock to inventory. Perkett Direct - Revenue Requirement Page 31 RR1-542 of

23 I B. Affiliate Charges in Capital Additions 2 Q. Earlier, you stated that a portion of SPS's requested capital additions reflects 3 affiliate charges. What regulatory standard did SPS use in preparing its direct 4 case on affiliate transactions? 5 A. According to Section of the Public Utility Regulatory Act and Railroad 6 Commission of Texas v. Rio Grande Gas Company,8 SPS has the burden of proof to 7 show that: (1) the affiliate charges, and services underlying those charges, are 8 reasonable and necessary for each item or class of items; (2) the charge from the 9 supplying affiliate (e.g., XES) to SPS for a service is no higher than the charge by the 10 supplying affiliate to any other entity (e.g., PSCo) for the same or similar service;9 11 and (3) the charge from the supplying affiliate to SPS reasonably approximates the 12 supplying affiliate's costs to provide the service (i.e., no profit). My testimony 13 regarding affiliate charges in capital additions will establish that SPS meets this 14 regulatory standard. 15 Q. Please describe the affiliate costs included in capital additions. 16 A. Affiliate costs included in capital additions are those costs charged either by XES or 17 another Operating Company to a SPS-specific capital work order for construction of 18 an asset owned and utilized entirely by SPS where the construction has been closed to 19 plant-in-service before the end of the Test Year. The terms "affiliate cost" and "XES 683 S.W.2d 783 (Tex. App. - Austin 1984, no writ). The affiliates charging capital costs to SPS do not perform work for unaffiliated entities except for mutual aid assistance. Perkett Direct - Revenue Requirement Page 32 RR1-543 of

24 1 charge" are synonymous in this discussion and are defined to include costs from all 2 Xcel Energy legal entities other than SPS. Also, "work order" and "subledger" are 3 synonymous in this discussion and refer to the number assigned to all construction 4 cost components to facilitate the grouping of the charges related to the construction 5 of a particular fixed asset. Lastly, "capital additions" and "plant additions" are the 6 same and along with "CWIP closings to plant-in-service" represent the two sides to 7 an accounting transaction that moves the finished asset from CWIP to plant. 8 Q. Is it possible to derive this information from the information submitted with 9 your direct testimony? 10 A. Yes. The information was first presented in Attachment LHP-RR-1 showing the total 11 affiliate costs included in plant-in-service for the defined period (July 1, through June 30, 2013). The affiliate costs came from either an XES charge 13 (Column I) or another Operating Company (Column J). A third column was 14 provided totaling the affiliate charges per work order (Column K). The charges are 15 those that were part of the amount closed to plant-in-service in the given period, such 16 that the charges were part of rate base. As with all construction that was in process 17 before July 1, 2013, the affiliate costs included in Attachment LHP-RR-1 18 incorporated any charges that were part of construction prior to July 1, 2013 but 19 became used and useful plant within the period July 1, 2012 through June 30, Perkett Direct - Revenue Requirement Page 33 RR1-544 of

25 1 Q. Can you give an example of an affiliate cost in a construction work order? 2 A. Yes. As an example, if an XES employee worked one hour on a construction project 3 and an SPS employee worked one hour on the same project, there would be two labor 4 hours charged. Assuming both employees have a labor rate of $25 per hour, the work 5 order would contain $50 in labor. Adding $100 of materials purchased by the SPS 6 employee and installed, the work order total would be $150. Assuming the work 7 order was closed to plant-in-service by June 30, 2013, the charges would be part of 8 rate base. Thus, $150 would be in rate base in this case and $25 of this $150 total 9 would be the affiliate costs included in rate base. 10 Q. Have you provided a summary of the information provided in Attachment 11 LHP-RR-1? 12 A. Yes. The information, from Attachment LHP-RR- 1 has been compressed to show a 13 summary by asset class of the work orders that closed to plant-in-service during the 14 period July 1, 2012 through June 30, This summarized worksheet is provided 15 on the first page in Attachment LHP-RR-1. The summary worksheet, "Summary of 16 by Asset Class" shows total plant additions for all work orders, whether or not they 17 had affiliate charges. The summary for all work orders that became part of rate base 18 for the period mentioned above are also summarized in the following table: Perkett Direct - Revenue Requirement Page 34 RR1-545 of

26 1 Table LHP-RR-4 Capital Additions in Rate Base (Total Company) Affiliate Costs Native Costs Total Costs Production $4,672,703 $137,945,118 $142,617,821 Transmission $3,389,149 $151,521,595 $154,910,744 Distribution $124,904 $52,848,753 $52,973,657 General $2,740,153 $24,308,214 $27,048,367 Software $6,928,888 $1,179,304 $8,108,192 Total $17,855,796 $367,802,984 $385,658,781 2 The discussion on the appropriateness of the inclusion of affiliate costs in rate 3 base centers on only the $17,855,796 shown above. 4 Q. Please explain the cost components for the affiliate charges to construction. 5 A. Attachment LHP-RR-2 provides a further breakdown of the affiliate costs into 6 various cost components. These cost components are standard construction costs 7 such as direct costs for labor and materials, and support costs, such as equipment and 8 other related expenses. The following table shows the cost breakdown for the 9 affiliate costs separated into the software work orders and non-software work orders. Perkett Direct - Revenue Requirement Page 35 RR1-546 of

27 1 Table LHP-RR-5 Cost Component Breakdown of Affiliate Costs in Plant Additions (Total Company $) Software All Other Total Work Work Orders Work Orders Orders Contract Work $5,959,993 $3,521,386 $9,481,380 Materials and Supplies $732,012 $2,020,302 $2,752,314 Labor $229,551 $5,377,397 $5,606,948 Other $7,332 $7,823 $15,155 Total $6,928,888 $10,926,908 $17,855, The pie chart below summarizes this data for the total affiliate costs included in plant additions. As one can see, 99.9% of the costs are contained in three cost categories: Contract Work, Labor and Materials and Supplies. Chart LHP-RR-1 6 Perkett Direct - Revenue Requirement Page 36 RR1-547 of

28 1 Q. Please define each of the cost components. 2 A. The definitions are based on the FERC Uniform System of Accounts, in the Electric 3 Plant Instructions, Section 3, Components of Construction Cost.10 The charges 4 contained in Attachment LHP-RR-1 are further divided into the object accounts that 5 were used when recording costs in the accounting systems, which facilitated the 6 breakdown of cost components as shown in Attachment LHP-RR-2. A listing of the 7 object accounts that were used to recognize affiliate charges is provided in 8 Attachment LHP-RR-4. The object accounts listed in LHP-RR-4 have been grouped 9 by the FERC Cost Component categories used in LHP-RR Q. Please explain the costs designated as "Contract Work" provided in Attachment 11 LHP-RR A. The largest of the affiliate cost components, totaling $9,481,380 and representing % of total affiliate charges, is Contract Work. The contract work being done 14 and charged through XES is directly related to various contracts that were entered 15 into on behalf of the Operating Companies including SPS. These costs can relate to 16 all aspects of construction, but most often are related to the labor component of 17 construction. About 62.86% of the contract work was related to the development of 18 software (totaling $5,959,993) CFR Part 101, Electric Plant Instruction No. 3, Components of Construction Cost (2013). Perkett Direct - Revenue Requirement Page 37 RR1-548 of

29 1 Q. Please explain the costs designated as "Labor" provided in Attachment 2 LHP-RR-2. 3 A. The Labor category includes costs for services provided to SPS by XES employees. 4 Services provided by an outside vendor, hired by XES, are recognized in contract 5 work. The labor cost component includes the direct time spent by SPS employees on 6 construction work and any associated labor costs for XES employees for specific SPS 7 construction projects. 8 The employee will recognize the time spent on a particular work order in the 9 time system. The rate charged to the work order is based on the hourly cost of this 10 employee, including all loadings applicable to this employee. The typical loadings 11 are pension, insurance, payroll taxes, incentive, injuries and damages, and 12 non-productive time. If the employee incurs overtime pay during the work on this 13 construction project, then this also is included. Labor costs, totaling $5,606,948, 14 represent 31.40% of total affiliate costs. Approximately 4.09% of these costs are 15 related to the development of software. 16 Q. Please explain the costs designated as "Materials and Supplies" provided in 17 Attachment LHP-RR A. The material and supplies contained in the affiliate charges include items purchased 19 by an XES employee for a specific SPS construction project. The Materials and 20 Supplies component totals $2,752,314 and represents 15.41% of total affiliate 21 charges. This typically includes minor items used in construction. Larger material Perkett Direct - Revenue Requirement Page 38 RRI of

30 1 purchases (i.e., steel towers, concrete, conductor and poles) are bought directly by 2 SPS and not through XES. 3 Q. Are there any other cost components within the affiliate charges? 4 A. Yes. There are additional cost components, but collectively they represent only % of the total affiliate costs. These costs follow the same processing as the more 6 significant components. However, because the related costs are so small, these 7 components will not be discussed in any further detail. 8 Q. How were these affiliate cost components billed to SPS? 9 A. The construction affiliate charges were assigned in two direct manners: (1) costs 10 charged directly to the SPS work order, or (2) direct to a work order that is further 11 allocated to SPS. Of the total affiliate construction charges, 61.20% are directly 12 charged to an SPS construction work order when incurred. The costs directly 13 assigned to a construction project and then apportioned to the SPS work order are 14 those costs for construction-related software representing 38.80% of the affiliate 15 costs (this process is described later in my testimony.) Furthermore, there are 16 overhead costs that are allocated from a clearing work order, but even these are direct 17 charged to an SPS general work order and then spread among SPS-specific work 18 orders. Overhead costs are also discussed later in my testimony. Perkett Direct - Revenue Requirement Page 39 RR1-550 of

31 1 Q. Do the capitalized affiliate charges reasonably approximate XES's cost of 2 providing the service? 3 A. Yes. XES provides its services at cost. There is no component for profit in XES's 4 charges. 5 C. Software Construction 6 Q. How have software work orders been included in the list of capital additions? 7 A. The costs related to the construction of software from July 1, 2012 through June 30, included in rate base are separated in Attachment LHP-RR-2. The software 9 work orders are included in the "General" line when discussing plant assets. I have 10 split this "General" category into software and Other General Plant assets. The 11 General Plant category was separated so that it was evident that capitalized software 12 costs were included in the information provided. Capitalized software includes all 13 the systems SPS uses to run it business, such as JD Edwards, which is the accounting 14 general ledger system. 15 Q. Are affiliate costs for software direct-assigned to the SPS work orders? 16 A. In general, no. Although not a common occurrence, there is one software work order 17 in the test period that was direct-assigned. In this case, the project was 100% 18 attributable to SPS so it was not allocated in the same way as other software. 19 However, for the vast majority of software projects, affiliate costs are allocated each 20 month from a special allocating work order to each of the four Operating Companies, 21 including SPS. Each software project is given an allocating work order (five-digit Perkett Direct - Revenue Requirement Page 40 RR1-551 of

32 1 work order). Charges recognized each month are allocated to the Operating 2 Company's eight-digit construction work order based on predetermined percentages. 3 Q. Please explain further how costs related to software construction are charged to 4 SPS work orders. 5 A. Software is an intangible asset and, as such, is the only asset that is broken down into 6 each owner's fractional share in the construction process. These costs represent the 7 only fixed asset where a percentage of the total installation is placed on each 8 operating company's books. This is accomplished through a controlled and 9 systematic process. Costs are directly charged on the invoice or other source 10 document to the affiliate or affiliates benefiting from the service whenever possible. 11 If costs cannot be directly charged, then the costs are charged to a XES indirect work 12 order that will assign the costs using a cost causative method to the affiliates 13 benefiting from the software system application or service. For costs that can be 14 identified as benefiting a particular business area, those services would be charged to 15 a XES indirect work order using the approved allocation factor for that business area. 16 The five-digit work orders are similar to the indirect work orders, except at 17 the end of the process, SPS will own and control an asset. The steps followed are 18 outlined below: Before the costs are first recognized, a five digit work order is set up with all 20 of the associated eight-digit work orders, where all the costs will ultimately 21 reside The five-digit work order is assigned allocation percentages for each 23 Operating Company based on the use of the software system. Perkett Direct - Revenue Requirement Page 41 RR1-552 of

33 1 3. An XES employee enters the cost into the work management system, the time 2 system, or the general ledger using the five-digit work order The employee uses the XES company code of "50." 4 5. Before the XES billing routine can be done, an allocating routine takes all 5 charges in the five-digit work order and assigns costs based on the allocation 6 table that was established when the five-digit work order was created At the end of each month, these charges are sent through the XES billing 8 routine The entry with an eight-digit work order and a capital object account are 10 processed simply by changing the company code from "50" (for XES) to "13" 11 (for SPS) A bill is created that charges the cost of this work from XES to SPS. 13 Q. How are the allocations established for the five-digit work orders? 14 A. As stated earlier, each allocation table is established based on the nature and use of 15 the software system. For example Windows 2000 Part 2 Meter Reading Acquisition 16 System is the second phase of a Windows 2000 virtual server operating system 17 upgrade. The allocation basis chosen is based on the number of users of the overall 18 virtual servers Windows 2000 operating system from each Operating Company. An 19 example of this allocation for one month's charges is provided in LHP-RR-7. The 20 allocation percentage for this example and all the other five-digit work orders related 21 to software is provided in Attachment LHP-RR-5. The apportionment methods are 22 selected to reflect the underlying utilization of the system that is being allocated. Perkett Direct - Revenue Requirement Page 42 RR1-553 of

34 1 Q. Please explain the costs designated as "software purchases" included within 2 Materials and Supplies provided in Attachment LHP-RR-2? 3 A. There is no physical material associated with software. The main components of 4 software are the software programs for the system being used and the labor associated 5 with putting those programs into productive use based on the user's specific 6 requirements. The programs are licensed from the specific vendor that is chosen. 7 For example, the cost to license and use the programs of the Data Loss Prevention 8 Module is the material cost of the software. Some software publishers will provide 9 tangible items such as user and technical manuals and CDs or other media containing 10 the programs, but other software publishers will electronically transmit manuals and 11 the programs rather than provide tangible media. In either situation, however, the 12 cost associated with the software is the license to use the software. 13 Q. How were these software purchase costs billed to SPS? 14 A. XES uses the same method for charging a construction project as an SPS employee 15 uses, i.e., the employee directly assigns the cost to the SPS work order. To facilitate 16 the accumulation of construction costs for software, an allocation of the direct costs 17 is performed monthly based on pre-determined factors directly relating to the use of 18 the asset. This allocation is not the same as a dynamic allocator that changes as the 19 underlying factors evolve. 20 For example, consider a situation where, at the end of the construction period, 21 SPS owns a software asset that will be used to bill customers for electric service. Perkett Direct - Revenue Requirement Page 43 RR1-554 of

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