EXHIBIT JNW-1 J. NEAL WALKER EDUCATION BACKGROUND AND BUSINESS EXPERIENCE

Transcription

1 EXHIBIT JNW-1 J. NEAL WALKER EDUCATION BACKGROUND AND BUSINESS EXPERIENCE Neal Walker is currently the Vice President of Operations at Texas-New Mexico Power Company. Mr. Walker graduated from Texas Christian University in 1989 with a Bachelor's Degree in Business Administration. He graduated from LeTourneau University in 1995 with a Master's Degree in Business Administration. He has also completed executive education courses at Darden Graduate School, University of Virginia, and Texas Christian University. Mr. Walker has been employed by TNMP since He has worked at TNMP as a Contracts and Regulatory Projects Analyst, Pricing Analyst, Regulatory Affairs Specialist, Area Manager in Nocona/Olney, Business Unit Manager in North Texas and Lewisville, and Director of Customer Operations. In 2005, Mr. Walker was promoted to Vice President of Operations. In this capacity he is responsible for overall TNMP operations and engineering, Retail Electric Provider relations and customer service, and community relations. 49

2 EXHIBIT JNW-2 page 1 of 4 TEXAS-NEW MEXICO POWER COMPANY RATE CASE ANALYSIS RESIDENTIAL TEST YEAR- 12 MONTHS ENDING MARCH 31, 2008 As of August 9, 2008 Curre nt TNMP price per kwh $ Current TNMP price 1000kWh Proposed TNMP price per kw $ Proposed TNMP price 1000kV % kwh1000 $'s Current % P roposed %. RepCompany Product RateType h1000 Per Month of Bill of Bill 1 StarTex Power Perfect 10 Fixed % 27% 2 Amigo Energy Online 6-month Commitment Program Fixed % 27% 3 Stream Energy Six-Month Fixed Rate Plan Fixed % 26% 4 Dynowatt Residential 6 Month Cost Control Plan - G ET A FRE Fixed % 26% 5 Dynowatt Residential 6 Month Rate Escape Plan Fixed % 26% 6 LPT LLC A Liberty Power Home Independence Plan Fixed % 25% 7 Spark Energy, L.P. Spark Online Advantage SOA12NM Fixed % 25% 8 Gexa Energy Gexa Guaranteed 24 Fixed % 25% 9 YEP Guaranteed Savings & No Long Term Commitment Variable % 25% 10 Amigo Energy Online 24-month Commitment Program Fixed % 25% 11 Dynowatt Residential 12 Month Conserve & Earn Plan Fixed % 25% 12 Dynowatt Residential 12 Month Rate Escape Plan Fixed % 25% 13 StarTex Power Star "Secure" 3 Year Plan Fixed % 25% 14 Dynowatt Residential 24 Month Rate Escape Plan Fixed % 25% 15 Amigo Energy Online 12-month Commitment Program Fixed % 25% 16 Gexa Energy Gexa Guaranteed 12 Fixed % 25% 17 Gexa Energy Gexa Green 24 Fixed % 25% 18 Simple Power Simple 1 Promo Variable % 25% 19 Stream Energy One-Year Fixed Rate Fixed % 25% 20 Stream Energy Two-Year Fixed Rate Fixed % 25% 21 Ambit Energy Lone Star Select-6 Month Term Fixed % 22 Dynowatt 25% Residential 12 Month Cost Control Plan - GET $50 1 Fixed % 25% 23 YEP 12 Month Fixed Rate Guaranteed E-Plan Fixed % 24% 24 Spark Energy, L.P. Spark Online Advantage SOA1NM Variable % 24% 25 Dynowatt Residential 24 Month Cost Control Plan - GET $100 Fixed % 26 24% Gexa Energy Gexa Green 12 Fixed % 24% 27 StarTex Power Star "Secure" 2 Year Plan Fixed % 28 24% Stream Energy Green & Clean Plan (Fixed Rate) Fixed % 29 24% StarTex Power Star "Secure" 1 Year Plan Fixed % 24% Direct Energy Price Protection PIanTM Fixed % 31 24% Dynowatt Residential 12 Month Go Green Conserve & Earn P Fixed % 32 Spark 24% Energy, L.P. Spark Online Advantage SOA02NM Fixed % 33 24% Commerce Energy Sure Choice All-in Rate Fixed % 34 Commerce 24% Energy Sure Choice Plus All-in Rate Fixed % 35 YEP 24% Green Earth 100% Renewable E-Plan with Flexible Variable % 36 Amigo Energy 24% Online 3-month Commitment Program Fixed % 37 Stream Energy 24% Month-to-Month Plan Variable % 38 Stream Energy 24% Green & Clean Plan (Variable) Variable % 39 StarTex Power 23% Promotional Month to Month Variable % Gexa Energy 23% Power Plan Variable % Gexa Energy 23% Gexa Green Variable % Simple Power 23% Simple 12 Fixed % 23% Commerce Energy Clear Choice All-in Rate Fixed % Cirro Energy 23% Smart Pass 12 Variable % 23% Ambit Energy Lone Star Select-1 Year Term Fixed % 23% NMP TNMP 50

3 EXHIBIT JNW-2 page 2 of 4 TEXAS-NEW MEXICO POWER COMPANY RATE CASE ANALYSIS TEST YEAR- 12 MONTHS ENDING MARCH 31, 2008 As of August 9, 2008 Current TNMP price per kwh $ Current TNMP price 1000kWh Proposed TNMP price per kw $ Proposed TNMP price 1000kY I NMY I NMY kwh1000 $'s Current % Proposed % Ln. RepCompany Product RateType kwh1000 Per Month of Bill of Bill 46 YEP Green Earth 100% Renewable E-Plan with 12 Mont[ Fixed % 23% 47 Commerce Energy Clear Choice Plus All-in Rate Fixed % 23% 48 YEP 9 Month Fixed Rate Guaranteed E-Plan Fixed % 22% 49 Texpo Energy Texpo One Year Savings Plan Fixed % 22% 50 Mega Energy, LP 24 Month MEGA Plan Fixed % 22% 51 Green Mountain Energy Pollution Free- Reliable Rate Va riable % 22% 52 Reliant Energy Rate Reduction 24 eplan Fixed % 22% 53 Texpo Energy Try Us Out Plan Variable % 22% 54 Reliant Energy Monthly Flex eplan Variable % 22% 55 TXU Energy TXU Energy Texas Choice 24 Fixed % 22% 56 Ambit Energy Lone Star Select Month to Month Va riable % 22% 57 Reliant Energy Rate Reduction 24 Fixed % 22% 58 Green Mountain Energy Pollution Free Variable % 22% 59 Amigo Energy 100% Renewable Energy Serv ice Fixed % 22% 60 YEP 3 Month Fixed Rate Guaranteed E-Plan Fixed % 22% 61 Reliant Energy Monthly Flex Variable % 22% 62 Ambit Energy Ambit Certified Green Month to Month Variable % 22% 63 Texpo Energy Clear Blue Skies 100% Renewable 12 Month Plan Fixed % 21% 64 Mega Energy, LP 12 Month "Mega Man" Deal Fixed % 21% 65 Ambit Energy Heart of Texas Month to Month Plan Variable % 21% 66 Commerce Energy Sure Choice Va riable Variable % 21% 67 First Choi ce Power Simply Better Price Plan 6 Fixed % 21% 68 Reliant Energy Flex 100% Texas Wind Variable % 21% 69 U.S. Energy Savings Corp. Elect ricity Price Protection Program Fixed % 21% 70 Hudson Energy Services Texas Super Saver Fixed "/a 21% 71 TXU Energy TXU Energy Freedom Plan Fixed % 21% 72 Hudson Energy Services Texas Super Saver Fixed % 21% 73 B ri lliant Energy, LLC Brilliant Low Price 12 Month Guarantee Fixed % 20% 74 Texas Power Texas Power Plan Variable % 20% 75 Nueces Elec Coop Retail Residential Electri city- Co-op At-Cost Power Va riable % 20% 76 Gateway Power Se rv ices Tex Flex Plan Variable % 20% 77 Reliant Energy Reliant PowerTracker (SM) Variable % 20% 78 Hudson Energy Se rv ice s Texas Super Clean Fixed % 20% 79 Hudson Energy Se rv ices Texas Super Clean Fixed % 20% 80 First Choice Power Simply Better Price Plan Fixed % 19% Change Impact $ - $ % 0.00% 0.00% 51

4 EXHIBIT JNW-2 page 3 of 4 TEXAS-NEW MEXICO POWER COMPANY RATE CASE ANALYSIS TEST YEAR- 12 MONTHS ENDING MARCH 31, 2008 Residential Current Monthly Unit Total Customer Charge Metering Charge Base Rate Reduction Customer Charge Base Rate Reduction Metering Charge Transmission Charge kwh Distribution Chage kwh System Benefit Charge kwh Transmission Cost Recovery Factor kwh Base Rate Reduction Transmission Charge kwh Base Rate Reduction Distribution Chage kwh CTC kwh Rate Case Expense Surcharge kwh SBF Total $ Small Commercial Current Monthly Unit Total Customer Charge Metering Charge Base Rate Reduction Customer Charge Base Rate Reduction Metering Charge Transmission System Charge Distribution System Charge System Benefit Fund Charge , Transmission Cost Recovery Factor Base Rate Reduction Transmission Charge kw Base Rate Reduction Distribution Chage kw CTC kwh , Rate Case Expense Surcharge kwh , SBF , Total $

5 EXHIBIT JNW-2 page 4 of 4 TEXAS-NEW MEXICO POWER COMPANY RATE CASE ANALYSIS TEST YEAR- 12 MONTHS ENDING MARCH 31, 2008 Residential Proposed Monthly Unit Total Customer Charge $ $1.28 Metering Charge $ $2.18 Transmission System Charge $ $6.10 Distribution System Charge $ $21.54 CTC $3.06 SBF $0.65 TCRF ($0.00) 1000 ($0.02) RCE2 $ $0.21 RCE $ $0.31 Total Change $35.31 $ % Seconda ry Svc > 5kW NIDR Proposed Monthly Unit Total Customer Charge $ 4.27 Metering Charge $ Transmission System Charge $ Distribution System Charge $ CTC ,000 $ SBF ,000 $ 9.81 TCRF ( ) 35 $ (0.16) RCE ,000 $ 2.36 RCE ,000 $ 5.85 Total Change $ $ (83.27) -24% 53

6 EXHIBIT JNW-3 TNMP Service Territory.... M.'t lf W ' as roo t e q Ot,..ac s I #._ * ";1..,.tY, w._ t c ry I"..., -'-._,.,.,.., J :. '.a ;.... noaks west 3 _._.. _. _ i! Cnast ) 4 f 54

7 EXHIBIT JNW-4 TNMP Electric Customers to Total Non- Production O&M Expenses - Texas nnnn o o V A W Z Total Non-Production O&M Customers 55

8 EXHIBIT JNW-5 y O ++.+ V V W L L Q N O Co w Q. W c O '++ O Oa O. p O 3 O L L Q = O oe z u z C C C N C C G LO.iawom:) / s m N.4 H 4I' N 0 y 56

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10 EXHIBIT JNW-7 TNMP Comparison of Increases in Gross and Net Plant Gross Plant in Service $627,664 $655,633 $697,299 $723,442 $769,146 $781,354 Net Plant in Service $407,979 $421,625 $448,975 $460,923 $479,475 $476,508 Texas-New Mexico Power Company $1,000,000 p $500, Year Gross Rant in Service! Net Rant in Service 58

11 EXHIBIT JNW-8 TNMP System Average Interruption Duration Index (SAIDI): FORCED Cl) TNMP System Average Interruption Frequency Index (SAIFI): FORCED LA

12 EXHIBIT JNW-9 60

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15 EXHIBIT JNW-12 page 1 of 2 AFFIDAVIT OF ALICIA QUINONES STATE OF NEW MEXICO COUNTY OF BERNALILLO BEFORE ME, the undersigned authority, on this day personally appeared Alicia Quinones, who, upon proving her identity to me and by me being duly sworn, deposes and states the following: "My name is Alicia Quinones. I am of legal age, a resident of the State of New Mexico, and have never been convicted of a felony. "I hold the position of Manager, Insurance Services for PNM Resources, Inc. and its subsidiaries, which includes Texas-New Mexico Power Company. In this capacity, I coordinate and manage the insurance and enterprise risk management programs in Texas and New Mexico. "One of the requirements of PURA is that in order to receive a catastrophic property damage reserve fund, the utility must demonstrate that such fund is a lower cost alternative to purchasing commercial insurance. The proposed Catastrophic Reserve Fund for TNMP, as presented by PricewaterhouseCoopers, is intended to provide self-insurance for two areas: 1. Potential losses resulting from damage to excluded property (which includes transmission and distribution wires, poles and other small equipment) per the terms and conditions of the current property policy. 2. Coverage of the deductible provision of TNMP's property insurance policy. This includes all covered transmission and distribution equipment per the property policy and includes substations and switchyards. This coverage is for the $1 M per occurrence deductible provision in TNMP's current proper ty insurance policy. "Because of the history of catastrophic losses, there is very little, if any, insurance available to electric utilities for losses to non-covered T&D assets. When available, it is insufficient in coverage and very expensive in cost. Given these conditions, the utilization of a ratepayer funded, self-insurance fund is a viable alternative to commercial insurance. "The only cost-effective means for TNMP to provide protection from catastrophic natural losses is through a loss reserve such as the one proposed in this proceeding." 63

16 EXHIBIT JNW-12 of Further, Affiant says naught. SWORN TO AND SUBSCRIBED before me, Notary Public, on this to certify which witness my hand and seal of office. day of August, 2008, SEAL: /k/3..;,. NOTARY PUBLIC in and for the State of New Mexico * Atl Printed Name hev}^l Le,4 SI;eeitsm My Commission expires 64

17 AFFIDAVIT STATE OF TEXAS COUNTY OF DALLAS BEFORE ME, the undersigned authority, on this day personally appeared James Neal Walker, who, upon proving his identity to me and by me being duty swom, deposes and states the following: "My name is James Neal Walker. I am of legal age, a resident of the State of Texas, and have never been convicted of a felony. I certify that the foregoing direct testimony and exhibits, offered by me on behalf of Texas-New Mexico Power Company, are true and correct and based upon my personal knowledge and experience." Dlmst, JAMES?11 WALKER :f 11 SWORN TO AND SUBSCRIBED before me, Notary Public, on this e2' day of August, 2008, to certify which witness my hand and seal of office. SEAL: R y!.(nny BLACKWELL Notary Public STATE OF TEXAS My Comm. Exp "I-"26,t. A PU C in ar$d for the State of Texas P ri nted Name Z/j74 My Commission expires / ag K- wg fl- 4 r 49 L 65

18 PUC DOCKET NO BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS APPLICATION OF TEXAS-NEW MEXICO POWER COMPANY FOR AUTHORITY TO CHANGE RATES PREPARED DIRECT TESTIMONY AND EXHIBITS OF F. ALLAN BURKE ON BEHALF OF TEXAS-NEW MEXICO POWER COMPANY AUGUST 29,

19 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No TABLE OF CONTENTS 1. INTRODUCTION AND QUALIFICATIONS...1 II. PURPOSE AND OVERVIEW OF TESTIMONY ORGANIZATION AND DESCRIPTION OF TNMP'S REP LIAISON DEPARTMENT...2 IV. DESCRIPTION OF REP RELATIONS BILLING & TRANSACTION GROUP...5 V. CUSTOMER SERVICE GROUP...7 VI. SPECIAL PROJECTS GROUP...8 VII. REP RELATIONS COSTS...9 VIII. CALL CENTER SUPPORT...10 IX. PNM RESOURCES ACQUISITION COMMITMENTS...12 X. CONCLUSION...15 EXHIBIT FAB-1 Move-Ins Completed within 2 Days of Requested Date EXHIBIT FAB-2 Move-Ins with Construction Completed within 10 Days EXHIBIT FAB-3 Street Light Orders Completed Within 2 Days 67

20 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No I. INTRODUCTION AND QUALIFICATIONS 2 Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND PLACE OF 3 EMPLOYMENT. 4 A. My name is F. Allan Burke. I serve as Director of the REP Relations Department of 5 Texas-New Mexico Power Company. My business address is 4100 International Plaza, 6 Fort Worth, Texas, Q. ON WHOSE BEHALF ARE YOU TESTIFYING? 8 A. I am testifying on behalf of Texas-New Mexico Power Company ("TNMP" or "Company"). 9 Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL 10 EXPERIENCE. 11 A. I earned a Bachelor of Business Administration in Accounting in 1992 from The 12 University of Texas at Arlington. I obtained my Certified Public Accountant license in I have over 15 years of professional accounting experience, including financial 14 preparation and analysis, budgeting, and forecasting. 15 In March 1999, I joined Facility Works, Inc., an unregulated subsidiary of Texas-New 16 Mexico Power Company, as Controller. After a few weeks, it was determined that future 17 financial profitability of Facility Works was questionable and a decision was made to 18 terminate operations in October I returned in February 2000 to Texas-New 19 Mexico Power Company as a project manager for electric deregulation. In 2002, 1 was 20 promoted to Manager of the newly created REP Liaison Department, as a result of 21 deregulation in Texas. Shortly after the TNMP acquisition by PNM Resources in 2005, I 22 was promoted to Director - REP Relations. 23 I have not previously filed testimony before any regulatory body. 24 Q. PLEASE SUMMARIZE YOUR DUTIES AS THE DIRECTOR OF REP RELATIONS 25 FOR TNMP? 26 A. I am employed by TNMP and report directly to the Vice-President of Texas Operations 27 and am responsible for the REP Relations Department. The department is responsible 28 for providing a primary point of contact for market issues that affect TNMP's billing and 29 operations. The REP Relations Department handles the initial contact and resolution for 30 Market Participants. 1 68

21 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No Q. HAVE YOU PREPARED ANY EXHIBITS? 2 A. Yes. I am sponsoring Exhibits FAB-1 through FAB-3, which are attached to my 3 testimony. Each of these exhibits was prepared by me or under my direction and 4 control. The information contained in these exhibits is true and correct to the best of my 5 knowledge and belief. 6 II. PURPOSE AND OVERVIEW OF TESTIMONY 7 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? 8 A. The purpose of my testimony will be to be describe the role and responsibilities of the 9 REP Relations Department; how the REP Relations Department fulfilled the certain 10 requirements of the settlement agreement from the PNM Resources acquisition; discuss 11 how my department interacts and relies on the services from PNMR Services Company 12 ("PNMR Services"). Finally, I will discuss the improvements in TNMP's call center and 13 the adjustment that is included in the rate filing package. 14 Q. DO YOU SPONSOR ANY SCHEDULES IN THE RATE FILING PACKAGE? 15 A. I do not sponsor any specific schedules in the rate filing package, but I do support the 16 validity of the data as it pertains to the REP Relations Department, including the cost of 17 outsourcing TNMP's call center function. 18 III. ORGANIZATION AND DESCRIPTION OF TNMP'S REP RELATIONS 19 DEPARTMENT 20 Q. EXPLAIN THE ORGANIZATION AND EVOLUTION OF TNMP'S REP RELATIONS 21 DEPARTMENT. 22 A. The REP Relations Department was created as a result of TNMP's business separation 23 plan, which was required for the Company to implement deregulation. This department 24 resides entirely within the TNMP organization. As the demands of the market increased 25 during its infancy, the number of employees was increased to 3 in 2003, 7 in 2004, 12 in , 19 in 2006, and 16 in This was needed to accommodate the need for 27 increased responsiveness to support REPs, ERCOT and PUC requirements

22 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No TABLE 1: REP RELATIONS ORGANIZATION CHART REPRe1aEionS fkpa Q. 6 A. L;uS?ortIerSernce5pa[Prnleds REP BilCttg and hlerket Trarsactlons WHERE ARE THE DEPARTMENT'S PERSONNEL LOCATED? All personnel in the REP Relations Department are located in Texas. 7 8 TABLE 2: REP RELATIONS EMPLOYEE LOCATIONS 9 10 Q. PLEASE EXPLAIN IN MORE DETAIL THE TASKS THAT REQUIRED THE REP 11 RELATIONS DEPARTMENT TO INCREASE. 12 A. When the department was created in 2002, the Company could not foresee future 13 changes at ERCOT to improve the market, rulemaking and projects at the Commission, 14 and all the initial growing pains of the deregulated market in Texas. As a result, my 15 department was forced to take on more responsibilities over the years. The following is a 16 list of tasks and requirements that the REP Relations Department performs. 17 Representation at ERCOT and business lead at the PUCT; 18 Complex large customer billing; 19 Billing disputes and resolutions; 3 70

23 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No Transaction disputes and resolutions; 2 Oversight of load profiling and annual ESI ID validation; 3 Critical care and critical load designations; 4 Service order issues, including disconnects, reconnects, move-ins, and all 5 priority issues requested by REPs; 6 Weather moratorium determination and notification; 7 Meter reading validation and estimation; 8 Historical usage requests; 9 ERCOT mass transitions; 10 ERCOT manual processes and service order manual workaround processes. 11 Q. DID YOUR DEPARTMENT CHANGE AS A DIRECT EFFECT OF THE PNM 12 RESOURCES ACQUISITION OF TNMP IN 2005? 13 A. Yes. The REP Relations Department was changed to have more control and quality 14 assurance. As described in more detail in the testimony of TNMP witness Stacy R. 15 Whitehurst, the acquisition of TNMP by PNM Resources ("PNMR Acquisition") had 16 significant impacts and levied significant commitments on TNMP. I will discuss these 17 commitments later in my testimony. As a result, at the end of 2006, TNMP's Customer 18 Relations Department was merged into the REP Relations Department. This included 9 19 employees. 20 Q. HAVE THERE BEEN ANY SUBSEQUENT CHANGES TO YOUR DEPARTMENT? 21 A. Yes. In 2007, the department was reduced by 3 employees (1 Accounts Receivable 22 Analyst and 2 Customer Service Representatives). The work done by the A/R Analyst 23 was moved to PNMR Services while the work of the 2 CSRs was absorbed by the rest of 24 the department. 25 Q. DID THIS PROVIDE THE REPS AND END USE CUSTOMERS ANY BENEFITIS? 26 A. Yes..This gave the REP Relations Department control of the customer experience from 27 cradle to grave, created a central point of contact within the Company to minimize 28 confusion for new REPs entering the market, and streamlined the resolution of Market 29 Participant issues. 4 71

24 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No IV. DESCRIPTION OF REP RELATIONS BILLING AND TRANSACTION GROUP 2 Q. DESCRIBE THE FUNCTIONS OF THE REP RELATIONS BILLING AND 3 TRANSACTION GROUP. 4 A. The REP Relations Billing and Transaction Group ("RRBTG") consists of 7 employees. 5 This group responds to daily requests from both Company employees and Market 6 Participants. These requests include: 7 Rate changes - Complete testing in CIS system for all rate modifications and 8 make necessary rate changes for account billing. 9 Meter reading issues - Investigate meter reading issues by creating service 10 orders to verify meter reading and consumption and respond with resolution. 11 Disputes - Investigate and resolve REP disputes involving fees, bill amounts and 12 invoice issues, which may or may not result in adjustments to bills. 13 Complex billing - Monitor IDR (Interval Data Recorder) billing and transactions 14 for accuracy and completeness. 15 Day-to-day billing inquiries - Respond to REP inquiries concerning billing 16 accuracy or provide explanation on account charges according to our tariff. 17 ERCOT generated reports - Identify accounts where ERCOT is missing 18 consumption and complete billing in CIS system for the Missing Consumption 19 report. Notify appropriate personnel to complete meter changes for accounts 20 changing from Non-IDR to IDR for the IDR Requirement report. 21 Operation Reports - Clear meter reading exception table daily and bill accounts 22 with multiple estimations. Accept or reject backdated transactions. Investigate 23 and resolve transaction issues from UBBBHST report. 24 Monthly Accruals - Provide accounting department accrual information for 25 accounts that bill at the first of each month for prior month's consumption. 26 Historical Usage - Provide historical data at the request of entities using Letter of 27 Authorizations (LOA); 28 Critical Customers - Critical care and critical load status is updated and 29 maintained on an ongoing basis with correspondence to the REPs. 5 72

25 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No ERCOT reports - Review ERCOT generated reports, including Missing Report, which provides weekly updates of ESI IDs missing 867 transactions and 3 Responsiveness Changes, which provide ESI IDs to review for weather 4 sensitivity changes. 5 One-off Issues - All Safety Net and Priority requests are received and reviewed 6 by the RRBTG, who then submits needed service orders and monitors requests 7 for completion. 8 MarkeTrak/FastTrak - Resolve all MarkeTrak issues pertaining to inadvertent 9 gain issues, missing transactions, load profile corrections, annual validation of 10 load profiles, missing 997 accept transactions, data extract variation issues, 11 substation code updates, and requests to cancel pending transactions. 12 Operation Repo rts - Internal operational reports are reviewed for invalid CR 13 relationships, active premise without a REP assignment and internal set up 14 issues on accounts within Banner system; and 15 Mass transitions - Work with ERCOT and Providers of Last Resorts during mass 16 transitions. 17 Q. ARE THESE FUNCTIONS DUPLICATED ELSEWHERE WITHIN TNMP OR BY AN 18 ORGANIZATION WITHIN PNMR SERVICES COMPANY? 19 A. No. All the functions described above are only provided within the RRBTG. Due to the 20 complex issues and requests, it is a necessity for our department to rely on the service 21 of other departments within TNMP and PNMR Services to perform our normal duties. 22 Q. PLEASE EXPLAIN THE SERVICES THAT THE RRBTG RELIES ON FROM PNMR 23 SERVICES. 24 A. Our department is in constant communication, usually daily, with several departments 25 within PNMR Services: Regulatory Policy, Business Technology Services, and 26 Accounting. Our interaction with Regulatory Policy includes working through application 27 of TNMP's tariff, customer complaint resolution (both complaints initiated with the 28 Company and informal complaints at the PUC), implementing rate changes, escalating 29 certain REP issues. Our interaction with BTS includes required system changes due to 30 ERCOT Texas Set releases, changes in the Commission rules, improvements to 31 TNMP's billing systems for increased customers' benefits, desktop support, 6 73

26 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No communication, data repairs, and processing meter readings and invoices on a daily 2 basis. Our interaction with Accounting includes obtaining Accounts Receivable aging 3 information as well as REP payment information 4 l have reviewed the testimony of Whitehurst, Harkness and Teague that pertains to my 5 department and agree that the services provided to the RRBTG are necessary and 6 reasonable. 7 V. CUSTOMER SERVICE GROUP 8 Q. DESCRIBE THE FUNCTIONS OF THE CUSTOMER SERVICE GROUP. 9 A. The Customer Service Group ("CSG") is located in League City, Texas. There are eight 10 employees within the CSG. Duties include main work functions along with basic office 11 activities such as accounts payable and reporting. The main work duties include: 12 Service Request - Add codes, as noted on report, to accounts to mark where a 13 meter is located, how to read a meter or any other instruction that is needed in 14 helping to read a meter. 15 Trouble & Skip Report - Review of report to see if an order is needed at any 16 location to check out a problem reported by meter reader. 17 Open Service Order - Review to identify order that are open and should be 18 closed. Contact responsible areas to close. 19 Service Orders - Issue and complete orders; re-reads; disconnect for non-pay; 20 reconnect after being disconnected for non-pay; turn-ons; turn-offs; meter 21 changes; out of cycle reads. 22 Dispatching - Dispatch orders that print during the day to field employees to be 23 worked, which includes aiding meter readers when they call in with questions or 24 concerns. 25 Answer phone calls - Respond to questions from TNMP Call Center and TNMP 26 Customers; take information from field employees to complete service orders. 27 Recycling Programs - Collection of office papers, plastics and aluminum then 28 delivered to collection facilities. 29 Q. ARE THESE FUNCTIONS DUPLICATED ELSEWHERE WITHIN TNMP OR PNMR 30 SERVICES? 7 74

27 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No A. No. All the functions described above are only provided within the CSG. Due to the 2 complex issues and requests, it is a necessity for our department to rely on the service 3 of other departments within TNMP and PNMR Services to perform our normal duties. 4 VI. SPECIAL PROJECTS GROUP 5 Q. DESCRIBE THE FUNCTIONS OF THE SPECIAL PROJECTS GROUP. 6 A. The Special Projects Group is located in For Worth, Texas, and currently consists of 1 7 employee. This group responds to daily processes within the Company. These 8 processes include: 9 Administration - Support of Field Collection System ("FCS") used to read electric 10 meters. Ensure routes are extracted from TNMP's CIS system and 11 imported into FCS two days ahead of scheduled read date. Ensure 12 routes are extracted from FCS and imported into TNMP's CIS system 13 on same day readings were taken. 14 Monitor performance and availability of FCS system and database. 15 Insure broken handhelds are sent back to the manufacturer for repair 16 and replaced with spare handhelds. 17 Troubleshoot and provide support for any questions or problems in 18 the field. Upgrade FCS with newer releases of the application when 19 available from the supplier, coordinating testing to ensure all previous 20 functionality works as required by the field. 21 Track and collect A/R invoices that exceed the required timeframe for 22 payment by REPs; provide monthly report to management on status 23 of all invoices aged over 31 days. 24 Conduct annual REP survey. 25 Compliance - Provide the Regulatory department operational performance for filing 26 TNMP's compliance reports. 27 Prepare assigned material and present at annual REP meeting. 28 Monitor weather reports for conditions meeting the requirements for 29 weather moratoriums and described in the Retail Market Guide. 8 75

28 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No Q. ARE THESE FUNCTIONS DUPLICATED ELSEWHERE WITHIN TNMP AND PNMR 2 SERVICES? 3 A. The Special Projects group is in constant communication, normally daily, with several 4 departments within PNMR Services: Regulatory Policy, Business Technology Services, 5 Treasury and Accounting. Our interaction with Regulatory Policy includes working 6 through the application of TNMP's tariff, customer complaint resolution (both complaints 7 initiated with the Company and informal complaints at the PUC), implementing rate 8 changes, and escalating certain REP issues. Our interaction with BTS includes required 9 system changes due to ERCOT Texas Set releases, changes in the Commission rules, 10 improvements to TNMP's billing systems for increased customers' benefits, desktop 11 support, communication, data repairs, and processing meter readings and invoices on a 12 daily basis. Our interaction with Accounting includes obtaining Accounts Receivable 13 aging information as well as REP payment information. I have reviewed the testimony of 14 TNMP witnesses Whitehurst, Rico, Harkness and Teague and agree that the services 15 provided to the Special Projects group are necessary and reasonable. 16 VII. REP RELATIONS COSTS 17 Q. WHAT ARE THE TOTAL TEST YEAR COSTS FOR THE REP RELATIONS 18 DEPARTMENT WHICH TNMP IS REQUESTING RECOVERY OF IN THIS CASE? 19 A. TNMP is requesting recovery of the expenses incurred by the REP Relations 20 Department. The following table describes the specifics: 21 TABLE 3: EMPLOYEE LOCATIONS --- REP Re tions - Straight Time-General Overtime-General Vacation Holiday Paid Absence Time Off Allowances Illness Employee Expense Meals Outside Services/ Other Test Year $514,523 1,218 62,910 28,935 7,481 (982) ,511 7, Total 9 76

29 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No Q. PLEASE EXPLAIN THE BUDGETING AND BUDGET PERFORMANCE TRACKING 2 PROCESS USED BY YOUR DEPARTMENT. 3 A. The REP Relations Department puts together an annual budget which must be reviewed 4 initially by the Vice-President of Texas Operations, then by the Senior Vice President of 5 Operations, and finally by the Utilities President. The REP Relations Department is then 6 expected to update the budget, if necessary, which instills careful cost planning and 7 discipline within the function. REP Relations Department is then held accountable for 8 this budget through monthly variance reports, where budgeted costs are compared to 9 actual costs. If the REP Relations Department is significantly under or over budget, it 10 will be reviewed and the department must justify the disparity to upper management, 11 who then may reduce their budget going forward or impose strict cost cutting measures. 12 Q. HOW HAS YOUR DEPARTMENT PERFORMED AGAINST BUDGET TARGETS? 13 A. The department consistently performs under budget. The largest non-labor expense in 14 the department is travel, which is carefully monitored. 15 VI11. CALL CENTER SUPPORT 16 Q. PLEASE DESCRIBE THE HISTORY OF TNMP'S CALL CENTER? 17 A. Since the beginning of deregulation, TNMP has tried to improve its call center function 18 and reduce that expense. Early on in deregulation, each TNMP local office was 19 responsible for handling their own customer calls during the day and used individual 20 third-party answering services for after-hours, weekend, and holiday calls. In order to 21 improve efficiency and provide increased and consistent customer service, TNMP 22 moved the normal business hour call handling responsibilities to the League City Service 23 Center and the after-hours responsibilities to a single third-party answering service. This 24 allowed TNMP the ability to handle 24 customer calls concurrently, compared to 1 or 2 25 concurrent customers handled in the local offices. 26 Q. HOW MANY CALLS PER HOUR OR PER DAY DID THE LEAGUE CITY SERVICE 27 HANDLE DURING NORMAL BUSINESS HOURS? 28 A. The total number of calls and cost per call for the normal business hour customer calls 29 cannot be obtained due to inadequate technology. The League City Service Center was 30 not able to handle increased call volumes during an electrical outage; customers would 31 receive a busy signal

30 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No Q. DID TNMP MANAGEMENT HAVE CONCERNS ABOUT THE CALL CENTER IN 2 LEAGUE CITY AND THE THIRD PARTY AFTER-HOURS COMPANY? 3 A. Yes. TNMP management was concerned with the inability to handle high call volumes 4 at the League City Service Center, and equally concerned with the third-party vendor 5 due to their lack of knowledge of the electric market and TNMP's service territory. 6 Q. HOW DID TNMP SEEK IMPROVEMENT? 7 A. Shortly after the PNMR Acquisition, TNMP began relying upon a subsidiary of PNM 8 Resources to provide call center support. The initial process rolled the after-hours calls 9 to the PNM call center instead of the third party company. This transition was scheduled 10 to be completed by the end of But events in September 2005 led TNMP to initiate 11 the migration of all the calls to PNM at that time. The full migration was completed in 12 April Q. WHAT EVENTS OCCURRED IN SEPTEMBER 2005? 14 A. The third party company handling the after-hours calls and TNMP's League City call 15 center are located in the Gulf Coast area, and were in the path of Hurricane Rita. 16 Hurricane Rita shut down the call centers, and all TNMP calls were temporarily 17 transferred to PNM's call center. Technical systems worked well and calls were 18 absorbed into the normal work flow without incidents. 19 Q. ARE THE EVENTS OF SEPTEMBER 2005 WHAT LED TO THE FULL MIGRATION 20 OF CALLS TO PNM CALL CENTER? 21 A. Yes. In addition to the success that occurred with the migration of calls to PNM in an 22 emergency, PNM's call center representatives began to receive a minimum of classroom hours devoted to learning the intricacies of the Texas deregulated market. 24 This training was on top of PNM's normal call center training. By December 2005, all 25 TNMP after-hours calls were transferred from TNMP's third party call center to the PNM 26 Call Center and Emergency dispatch. By April 2006, all calls were transferred to the 27 PNM call center. 28 Q. HOW WAS THE RATE DETERMINED BETWEEN TNMP AND PNM? 29 A. TNMP was paying approximately $1 per call for after-hour call services with its third 30 party call center. Based on an estimated number of calls provided by TNMP, PNMR 31 Services calculated the amount per call to be approximately $0.45. Unfortunately, based 11 78

31 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No on the inability to track inbound calls at the League City Call Center and several REPs 2 changing their billing and call center processes, TNMP underestimated the calls by five- 3 fold. TNMP and PNM decided to renegotiate the rate based on the higher demands that 4 TNMP has placed on the PNM call center. 5 Q. DOES TNMP PAY PNM AN ADDER OR PREMIUM FOR USE OF THE CALL 6 CENTER? 7 A. No. The amount calculated is based on actual costs incurred by PNM with no adder of 8 premium charge. 9 Q. ARE THE PRO FORMA COSTS FOR THE CALL CENTER NECESSARY AND 10 REASONABLE? 11 A. Yes. Based on the quality of product, the importance of the function and the ability to 12 have a call center that is not directly affected by hurricanes demonstrates the necessity 13 of the expenses. The reasonableness of the charges is demonstrated by TNMP being 14 able to negotiate a rate with PNM, which was verified through a third party. This rate 15 does not contain an adder or premium for service. 16 IX. PNM RESOURCES ACQUISITION COMMITMENTS 17 Q. PLEASE PROVIDE A HIGH LEVEL SUMMARY OF TNMP'S COMMITMENTS. 18 A. As part of the PNMR Acquisition, TNMP committed to certain standards and 19 performances that affect my department. Specifically, TNMP agreed to the following: 20 REP Meetings - The purpose of such meetings will be to allow discussion of 21 TNMP's practices and policies and to permit REPs to provide comments to 22 TNMP on such practices and policies. 23 FasTrak - In the event an issue raised by a REP is not capable of being resolved 24 within seven (7) business days, TNMP shall provide the affected REP with a time 25 schedule for resolution of the issue no later than the seventh business day. 26 TNMP shall use due diligence in resolving all ERCOT and Non-ERCOT FasTrak 27 issues raised by REPs. 28 Cancel Rebills - TNMP is committed to working with REPs to resolve 29 cancellation/rebill issues in a timely manner. In the event an issue is not capable 30 of being resolved within seven (7) business days, TNMP shall provide the 12 79

32 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No affected REP with a time schedule for resolution of the issue no later than the 2 seventh business day. TNMP shall use due diligence in resolving all 3 cancellation/rebill issues. 4 LOAs - TNMP agrees to use due diligence to respond to letters of authorization 5 within five (5) business days as contemplated by the ERCOT Retail Market 6 Guide. 7 REP Access to data - TNMP shall investigate the feasibility of providing REPs 8 with direct access to specific customer, non-idr historical metering data via the 9 Internet. 10 Viewing of customer usage - TNMP shall provide customer usage information in 11 accordance with the terms set forth in of the TNMP tariff for retail delivery 12 service. 13 Complex billing - TNMP shall investigate changing its billing system to 14 accommodate a more complex billing statement. 15 IDR billing - TNMP shall establish a process under which an employee will be 16 dedicated to reviewing each IDR meter reading for accuracy. 17 Q. HAS TNMP SUCCESSFULLY FULFILLED THE REQUIREMENT OF HOSTING AN 18 ANNUAL REP MEETING? 19 A. Yes. TNMP held REP Annual meetings on June 29, 2005, October 19, 2006, and 20 October 30, The presentations are available on TNMP's website, including the 21 ability to suggest topics and or ask questions. 22 Q. HAS TNMP SUCCESSFULLY FULFILLED THE REQUIREMENT OF RESOLVING 23 FASTRAK AS REQUIRED BY ARTICLE XIV, SECTION B OF THE STIPULATION? 24 A. Yes. The REP Relations Department created the Retail Market Transaction Group and 25 has a dedicated address for this group for Market Participants to submit their 26 issues. 27 Q. HAS TNMP SUCCESSFULLY FULFILLED THE REQUIREMENT OF RESOLVING 28 CANCEL REBILLS? 29 A. Yes. The REP Relations Department created the REP Relations Billing Group to provide 30 additional quality assurance on the billing process, and to minimize cancel rebilling. The 13 80

33 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No REP Relations Billing Group has a dedicated address for Market Participants to 2 submit their issues. 3 Q. HAS TNMP SUCCESSFULLY FULFILLED THE REQUIREMENT OF PROCESSING 4 LOAS? 5 A. Yes. One of the functions of the Retail Market Transaction Group is to handle LOAs. 6 The LOA process has a dedicated address for Market Participants to submit their 7 requests. 8 Q. HAS TNMP SUCCESSFULLY FULFILLED THE REQUIREMENT OF ALLOWING 9 REPS TO HAVE ACCESS TO CUSTOMER DATA VIA THE INTERNET? 10 A. Yes. The requirement was for TNMP to work with the Alliance for Retail Markets by 11 March 1, 2005 to determine whether such access is reasonably feasible. While REPs do 12 not have specific logins to view non-idr customers' data, TNMP allows customers to 13 sign up for logins, and at their discretion, allows their REP to have access to this 14 information. 15 Q A. 18 Q A. 21 Q A HAS TNMP SUCCESSFULLY FULFILLED THE REQUIREMENT OF ALLOWING CUSTOMERS TO HAVE ACCESS TO DATA? Yes. HAS TNMP SUCCESSFULLY FULFILLED THE REQUIREMENT OF COMPLEX BILLING? Yes. TNMP has recently installed the Lodestar billing system. HAS TNMP SUCCESSFULLY FULFILLED THE REQUIREMENT OF A DEDICATED IDR EMPLOYEE? Yes. TNMP's invoicing processing to REPs holds all IDR invoices, and must be manually released after verification. This position resides in the REP Relations Billing Group. 26 Q. HAS TNMP SUCCESSFULLY FULFILLED THE REQUIREMENT OF CUSTOMER A. SERVICE STANDARDS? Yes. Please see Exhibits FAB-1 and FAB

34 DIRECT TESTIMONY OF F. ALLAN BURKE PUC DOCKET No Q. HAS TNMP SUCCESSFULLY FULFILLED THE REQUIREMENT OF CUSTOMER 2 SERVICE STANDARDS FOR LIGHT REPLACEMENT? 3 A. Yes. Please see Exhibit FAB-3. 4 X. CONCLUSION 5 Q. WHAT ACTION DO YOU PROPOSE THAT THE COMMISSION TAKE IN THIS 6 PROCEEDING? 7 A. Based on my testimony, I propose the Commission find that the REP Relations 8 Department, including all groups within the department, and call center expenses are 9 just and reasonable, and should be included in TNMP's overall cost of service. In 10 addition, the Commission should allow all expenses and capital investments that were 11 made as part of the PNMR Acquisition settlement be included in TNMP's cost of service. 12 Q. DOES THIS CONCLUDE YOUR TESTIMONY? 13 A. Yes, it does

35 EXHIBIT FAB-1 oo: CD Q 41 L. a a cr 4.. a N... L Q..:: O (N C; Q CL O y g C,. o -- LO C C: cl a; th?` 83

36 EXHIBIT FAB-2 2 LL le d CO ` O d ]ti Rl 0 O cy1 t -O CL E 0 U 0 :. U fa U cy C N 0 d 84

37 EXHIBIT FAB-3 co 0 C3 N.,..::. ta ',. w-; o., so N ar...:.. `... a.,,... t1y`, -'CLt Q T O 2t V d OCV 85

38 AFFIDAVIT STATE OF TEXAS COUNTY OF TARRANT BEFORE ME, the undersigned authority, on this day personally appeared F. Allan Burke, who, upon proving his identity to me and by me being duly sworn, deposes and states the following: "My name is F. Allan Burke. I am of legal age, a resident of the State of Texas, and have never been convicted of a felony. I certify that the foregoing direct testimony and exhibits, offered by me on behalf of Texas-New Mexico Power Company, are true and correct and based upon my personal knowledge and experience." F. ALLAN RKE SWORN TO AND SUBSCRIBED before me, Notary Public, on this day of August, 2008, to certify which witness my hand and seal of office. SEAL: OF L INNY BLACKWELL Notary Public STATE OF TEXAS My Comm. Exp. 031{NSl2012 NOT RY PU!C in for the State of Texas Printed Name la-a "e., My Commission expires,,r'"- 86

39 PUC DOCKET NO BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS APPLICATION OF TEXAS-NEW MEXICO POWER COMPANY FOR AUTHORITY TO CHANGE RATES PREPARED DIRECT TESTIMONY OF TONY B. THOMPSON ON BEHALF OF TEXAS-NEW MEXICO POWER COMPANY AUGUST 29,

40 DIRECT TESTIMONY OF TONY B. THOMPSON PUC DOCKET No TABLE OF CONTENTS 1. INTRODUCTION AND QUALIFICATIONS...1 II. PURPOSE AND OVERVIEW OF TESTIMONY...2 III. TNMP'S TEST YEAR ENERGY EFFICIENCY PROGRAMS...2 IV. TNMP'S ENERGY EFFICIENCY GOALS AS SET FORTH IN DOCKET NO V. SPECIFIC TNMP CHALLENGES TO MEETING ENERGY EFFICIENCY GOALS...7 VI. IMPACT OF HOUSE BILL 3693 AND SUBSTANTIVE RULE ON TNMP'S ENERGY EFFICIENCY PROGRAMS...9 VII. TNMP'S 2008 ENERGY EFFICIENCY PROGRAM OFFERING...11 VIII. TNMP'S 2009 ENERGY EFFICIENCY PROGRAM OFFERING...12 X. SUMMARY AND CONCLUSION...13 i 88

41 DIRECT TESTIMONY OF TONY B. THOMPSON PUC DOCKET No I. INTRODUCTION AND QUALIFICATIONS 2 Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND PLACE OF 3 EMPLOYMENT. 4 A. My name is Tony B. Thompson. I am a Regulatory and Pricing Specialist employed by 5 PNMR Services Company ("PNMR Services"), a shared services organization and 6 wholly owned subsidiary of PNM Resources, Inc. ("PNM Resources"), providing 7 regulatory and other support to Texas-New Mexico Power Company. My business 8 address is 225 E. John Carpenter Freeway, Suite 1500, Irving, Texas Q. ON WHOSE BEHALF ARE YOU TESTIFYING? 10 A. I am testifying on behalf of Texas-New Mexico Power Company ("TNMP" or "Company"). 11 Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL 12 EXPERIENCE. 13 A. I hold a Bachelor of Science degree in Industrial Engineering from Texas A&M 14 University, and a Master of Business Administration from Dallas Baptist University. My 15 professional experience includes providing testimony to the Federal Energy Regulatory 16 Commission, requests for approval of Certificates of Convenience and Necessity, 17 numerous comments on rulemaking projects, and filing compliance reports at the Public 18 Utility Commission of Texas for TNMP and other PNM Resources affiliates. 19 Q. PLEASE SUMMARIZE YOUR DUTIES AS A REGULATORY AND PRICING 20 SPECIALIST IN REGARD TO TNMPS' ENERGY EFFICIENCY PROGRAMS. 21 A. Among my various duties as a Regulatory and Pricing Specialist, I serve as program 22 manager for TNMP's energy efficiency programs and I am the Company's regulatory 23 liaison for all energy efficiency matters. 24 Q. HAVE YOU TESTIFIED BEFORE IN REGULATORY PROCEEDINGS? 25 A. Yes. I have previously filed testimony before the Public Utility Commission of Texas 26 ("PUCT") in Docket No

42 DIRECT TESTIMONY OF TONY B. THOMPSON PUC DOCKET No PURPOSE AND OVERVIEW OF TESTIMONY 2 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? 3 A. The purpose of my testimony is to provide a description of TNMP's energy efficiency 4 programs and activities during the test year, including a review of the programs' budgets, 5 costs and results. I will also discuss the impact of P.U.C. SUBST. R ("S.R. 181") 6 on the Company's current programs. This testimony also presents the challenges 7 TNMP faces to meet energy efficiency goals, and a preview of the new and existing 8 energy efficiency programs for beyond the test year in 2008 and This preview 9 also includes a discussion of the programs' budgets. 10 Q. DO YOU SPONSOR ANY EXHIBITS OR SCHEDULES INCLUDED WITH THIS RATE 11 FILING PACKAGE? 12 A. No, there are no exhibits or schedules to accompany this testimony. I do sponsor the 13 tables and graphs which are embedded in my testimony. 14 Q. WAS THIS TESTIMONY PREPARED BY YOU OR UNDER YOUR SUPERVISION? 15 A. Yes, my testimony, including embedded tables and graphs, was prepared by me or 16 under my direction and control. The information contained in this testimony is true and 17 correct to the best of my knowledge and belief TNMP'S TEST YEAR ENERGY EFFICIENCY PROGRAMS 19 Q. PLEASE DESCRIBE TNMP'S ENERGY EFFICIENCY PROGRAMS IN PLACE 20 DURING THE TEST YEAR OF APRIL 1, 2007 THROUGH MARCH 31, A. TNMP implemented the following energy efficiency programs during the test year: 22 Large Commercial Standard Offer Program ("COM SOP"): 23 COM SOP targets Large Commercial customers with a maximum demand of more 24 than 100 kw. Incentives are paid to project sponsors for certain energy efficiency 25 measures installed in new or retrofit applications that provide verifiable demand and 26 energy savings. 27 Residential and Small Commercial Standard Offer Program ("RES COM SOP"): 28 RES COM SOP targets residential customers and small commercial customers 29 whose maximum demand is less than 100 kw. Incentives are paid to project 2 90