BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO * * * * * ) ) ) ) ) DIRECT TESTIMONY OF JEFFREY C.

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1 Page of BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO IN THE MATTER OF THE APPLICATION OF PUBLIC SERVICE COMPANY OF COLORADO FOR APPROVAL OF ITS 0 0 RENEWABLE ENERGY COMPLIANCE PLAN * * * * * PROCEEDING NO. A-XXXXE DIRECT TESTIMONY OF JEFFREY C. HASKINS ON BEHALF OF PUBLIC SERVICE COMPANY OF COLORADO February, 0

2 Page of BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO IN THE MATTER OF THE APPLICATION OF PUBLIC SERVICE COMPANY OF COLORADO FOR APPROVAL OF ITS 0 0 RENEWABLE ENERGY COMPLIANCE PLAN * * * * * PROCEEDING NO. A-XXXXE SUMMARY OF THE DIRECT TESTIMONY OF JEFF HASKINS 0 Jeff Haskins is the Renewable Energy Portfolio Manager, Purchase Power, at Xcel Energy Services, Inc., a wholly-owned subsidiary of Xcel Energy Inc., the parent company of Public Service Company of Colorado. The purpose of Mr. Haskins s testimony is to support the sections of the 0 Renewable Energy Plan ( RE Plan or Plan relating to Renewable Energy Credits ( RECs. Mr. Haskins prepared Section of Attachment RLK- and Tables - through - of Attachment RLK- of the RE Plan. Mr. Haskins explains that Table - in Attachment RLK- sets forth the RECs that Public Service plans to acquire and retire during the 0 through 0 compliance years. He explains how the REC bonuses set forth in that table comply with Commission Rules (e, (f and (i and SB -. He also explains that Public Service s anticipated REC transfers to wholesale providers pursuant to Commission Rule 0(l are set forth in Row of Table -. Mr. Haskins explains how the Company will retire RECs for the Windsource program to comply with the decision in Proceeding No. A-0E. As the

3 Page of 0 Windsource program is now sourced from Public Service s renewable portfolio, in 0 0, customers who purchase 00 percent of their energy from Windsource will pay a premium that assumes that they are purchasing 0 percent of their renewable energy under Windsource and 0 percent of their renewable energy under retail rates. Mr. Haskins explains how Public Service tracks RECs for compliance purposes. He explains that the Company uses an internal REC Tracking System to create, track, and count RECs. The system issues a REC for each megawatt-hour of renewable energy produced or purchased and assigns unique serial numbers to each REC to avoid double counting. Mr. Haskins also testifies regarding the Western Renewable Energy Generation Information System ( WREGIS. He explains that WREGIS is an independent, renewable energy registry and credit tracking system for electricity generation within the western states, including Colorado, which is operated by the Western Electricity Coordinating Council ( WECC. He explains how Public Service registers in WREGIS all RECs used for RES compliance, except Small Retail DG, pursuant to Commission Rule (j. For the 0 through 0 compliance years, Public Service plans to retire Non-DG and Wholesale-DG RECs for RES compliance in WREGIS.

4 Page of BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO IN THE MATTER OF THE APPLICATION OF PUBLIC SERVICE COMPANY OF COLORADO FOR APPROVAL OF ITS 0 0 RENEWABLE ENERGY COMPLIANCE PLAN * * * * * PROCEEDING NO. A-XXXXE SECTION INDEX PAGE I. INTRODUCTION and PURPOSE OF TESTIMONY... II. RENEWABLE ENERGY CREDITS... III. REC TRACKING... IV. WINDSOURCE PROGRAM... V. WESTERN RENEWABLE ENERGY GENERATION INFORMATION SYSTEM (WREGIS...

5 Page of GLOSSARY OF ACRONYMS AND DEFINED TERMS Acronyms/Defined Term 0 RE Plan, RE Plan, Plan, or Compliance Plan CSG DG DSM DSMCA ECA ERP kw kwh Large Retail DG MW NDA No RES Plan Non-DG O&M PCCA PTC Public Service or Company PV Meaning Public Service s 0-0 Renewable Energy Compliance Plan Community Solar Garden Distributed Generation Demand Side Management Demand Side Management Cost Adjustment Electric Commodity Adjustment Electric Resource Plan Kilowatt Kilowatt-hour Retail Distributed Generators > MW Megawatt Non-Disclosure Agreement Company s Plan to acquire only non-renewable resources Non Distributed Generation Operations and Maintenance Purchased Capacity Cost Adjustment Production Tax Credit Public Service Company of Colorado Photovoltaic

6 Page of Acronyms/Defined Term QRU R Rate RD TOU Rate RE REC RES RES Plan RESA Retail DG RFP S&F S*R Schedule RE SRCS Tariff TCA WECC Wholesale DG WREGIS Xcel Energy Qualified Retail Utility Standard Retail Rate Meaning Residential-Demand Time of Use Rate Renewable Energy Renewable Energy Credit Renewable Energy Standard Renewable Energy Standard Plan Renewable Energy Standard Adjustment Retail Distributed Generation Request for Proposal Service and Facilities Solar*Rewards Recycled Energy Service Solar*Rewards Community Service Tariff Transmission Cost Adjustment Western Electricity Coordinating Council Wholesale Distributed Generation Western Renewable Energy Generation Information System Xcel Energy Inc.

7 Page of BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO * * * * * IN THE MATTER OF THE APPLICATION OF PUBLIC SERVICE COMPANY OF COLORADO FOR APPROVAL OF ITS 0 0 RENEWABLE ENERGY COMPLIANCE PLAN PROCEEDING NO. A-XXXXE DIRECT TESTIMONY OF JEFF HASKINS I. INTRODUCTION AND PURPOSE OF TESTIMONY 0 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. A. My name is Jeff Haskins. My business address is 00 Larimer Street, Denver, Colorado 00. Q. BY WHOM ARE YOU EMPLOYED AND IN WHAT POSITION? A. I am employed by Xcel Energy Services, Inc., a wholly-owned subsidiary of Xcel Energy Inc., the parent company of Public Service Company of Colorado. My job title is Renewable Energy Portfolio Manager, Purchase Power. Q. ON WHOSE BEHALF ARE YOU TESTIFYING IN THE PROCEEDING? A. I am testifying on behalf of Public Service Company of Colorado ( Public Service or the Company.

8 Page of 0 0 Q. HAVE YOU INCLUDED A DESCRIPTION OF YOUR QUALIFICATIONS, DUTIES, AND RESPONSIBILITIES? A. Yes. A description of my qualifications, duties, and responsibilities is included at the end of my testimony following my conclusion. Q. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? A. The purpose of my testimony is to support the sections of the Company s 0-0 Renewable Energy Plan ( RE Plan or Plan relating to Renewable Energy Credits ( RECs. I am responsible for managing the Company s internal REC Tracking System (utilized for RECs generated from less-than--mw solar resources on our system and the Company s involvement in the Western Renewable Energy Generation Information System ( WREGIS. Q. WHAT SECTIONS OF THE PUBLIC SERVICE 0 RENEWABLE ENERGY COMPLIANCE PLAN DID YOU PREPARE? A. I prepared Section Estimates of Existing and Forecasted RECs in Attachment RLK- of the Plan, and Tables - through - in Attachment RLK-. Q. ARE THESE SECTIONS IN COMPLIANCE WITH THE COMMISSION S RENEWABLE ENERGY STANDARD RULES? A. Yes, these sections are in compliance with the Commission s RES rules.

9 Page of II. RENEWABLE ENERGY CREDITS 0 Q. PLEASE BRIEFLY DESCRIBE TABLE - IN ATTACHMENT RLK-? A. Table - details the RES requirements by resource type for the years 0 through 0 showing the quantity of RECs that are required for compliance retirements each year. Q. CAN YOU LEAD US THROUGH TABLE - IN GREATER DETAIL? A. Yes, Table - Column B shows the retail sales forecast the Company is using in the requirement calculations. Rows through contain the percentages applied to the retail sales based on the RES requirement each year. Column C shows the total RES requirement each year and column(s D through G detail the requirements by resource type. Q. PLEASE BRIEFLY DESCRIBE TABLE - IN ATTACHMENT RLK-. A. Table - provides information about the RECs and type of RECs Public Service plans to acquire in the 0 through 0 Compliance Years and the RECs that Public Service expects to retire to comply with the 0 through 0 RES. Q. CAN YOU LEAD US THROUGH TABLE - IN GREATER DETAIL? A. Certainly. More specifically, Table - contains by REC type, the amount of RECs the Company expects to have available and anticipates retiring for the 0 years 0 through 0 for RES compliance. These RECs are provided by fuel type within each REC category. For example, Row presents the 0 and 0 REC production is included in the plan tables to provide additional detail for the REC production and illustrate how the banked RECs are carried forward for the 0 RE Plan.

10 Page 0 of 0 0 subtotals for all eligible Wholesale-DG wind resources and Row 0 presents the subtotal for all eligible Wholesale-DG resources. Column B describes the REC category. Column E shows the resource capacity. Column(s F through J identifies the quantity of RECs generated for the various sources. Row s 0 through in Table - detail REC compliance requirements by resource type, REC bonuses, forecasted REC retirements, and REC balances that are carried forward. Q. WHAT REC BONUSES ARE BEING APPLIED? A. Commission Rule (e and (f provide for bonuses for each kilowatt-hour of eligible energy generated from a resource in Colorado or from a Community-Based project. For RES compliance, these rules allow a Qualifying Retail Utility ( QRU to count an in-state REC as. RECs or from a Community based project as. RECs. The in-state bonus for Retail DG included applies only to purchase transactions entered into prior to August, 00. Rows 0 and 0 in Table - reflect these rule provisions. Q. DID THE PASSAGE OF SB - AFFECT THE REC BONUS APPLIED? A. Yes. SB - allows for a. REC bonus on all resources, other than retail distributed generation, placed in service prior to January, 0. We assume that all incremental renewable resources placed in service prior to January, 0, will retain the REC bonus. However, this law does affect the three new eligible energy resources acquired in our last Electric Resource Plan:

11 Page of 0 MW Comanche Solar 0 MW Hooper Solar 0 MW Golden West Wind 0 Q. WHY IS THE COMPANY TRANSFERRING RECS TO OTHER PARTIES? A. If the wholesale customer agrees to pay the full costs associated with the acquisition of the eligible energy, Commission Rule 0(l requires that Public Service transfer RECs to the wholesale customer based on the wholesale customer s load ratio share of Public Service s total retail and wholesale energy deliveries. Row in Table - would reflect the Company s anticipated REC transfer obligations given Rule 0(l.

12 Page of III. REC TRACKING 0 0 Q. PLEASE SUMMARIZE TABLE -. A. Table - presents the projected RECs that the Company expects will be generated by existing resources in each category and resources acquired through the Company s Solar*Rewards programs and Solar*Rewards Community programs. Table - does not show the impact of the carry forward rule. For recycled energy, the Company will utilize a production meter to track the energy produced by customers recycled energy systems, and for compliance purposes, will equate one megawatt-hour produced to one compliance requirement. Q. PLEASE SUMMARIZE TABLE -. A. Table - also presents the projected RECs from a potential 0 MW solar facility not yet under contract to supply the Company s proposed Solar *Connect program. At this time it is assumed 00 percent of the RECs from the proposed facility will be retired on behalf of the customers under the program if it is approved. Q. HOW DOES THE COMPANY TRACK THE RECS FOR COMPLIANCE? A. The Company internally tracks RECs generated from less-than--mw solar resources on our system. For this purpose, the Company developed a REC Tracking System which became operational in mid-00. The internal database creates, tracks, and counts all RECs by type of renewable resource, date of generation, identification of the generator, and generation location. The REC Tracking System issues a REC for each megawatt-hour of

13 Page of 0 renewable energy Public Service produces or purchases through power purchase agreements. To ensure RECs are not double counted or retired for multiple purposes, the system assigns a unique serial number to each REC. All Non-DG and Wholesale-DG generators are registered in WREGIS and RECs from these generators have been loaded in WREGIS since January 00. Retail-DG generators greater than MW (large Retail-DG are registered in WREGIS and RECs from this generation have been loaded in WREGIS since Nov 00. The REC Tracking System was designed to ensure compatibility with WREGIS, and was reconciled with WREGIS to maintain consistency between the two systems during the transition phase from using the REC Tracking system to using WREGIS for tracking and reporting of all Non-DG, Wholesale-DG and large Retail-DG RECs which are now managed in WREGIS. Q. WHY ARE NOT ALL RETAIL DG SOLAR RECS TRACKED IN WREGIS? A. Pursuant to Commission Rule (j, effective December 0, 00, retail DG generators less than MW are exempt from registration in WREGIS. At this time the Company uses the REC Tracker system for retail DG REC tracking under MW.

14 Page of IV. WINDSOURCE PROGRAM 0 0 Q. PLEASE DESCRIBE HOW THE COMPANY WILL RETIRE RECS FOR THE WINDSOURCE PROGRAM TO COMPLY WITH THE DECISION IN PROCEEDING NO. A-0E? A. Green-e allows the Company to retire RECs that have a generation date from the last half of the prior year. Once these RECs are retired for Windsource, they cannot be used for REC transfers or RES compliance or sold to a third party. The Windsource REC retirements will be from Non-DG wind sources and will be detailed in our RES Compliance Reports. Q. IS THE WINDSOURCE PROGRAM THIRD-PARTY CERTIFIED? A. Yes. Green-e currently certifies the Windsource program and the Company expects to continue to use Green-e Energy to certify its Windsource program through 0. Q. HAS THE COMMISSION PREVIOUSLY APPROVED THE COMPANY TO RETIRE SPECIFIC TYPES OF RECS ON BEHALF OF WINDSOURCE CUSTOMERS? A. Yes. In Decision Nos. R-00 and C-0, the Commission approved the Company to retire non-dg RECs on behalf of customers. Consistent with that decision, the Company has been retiring only non-dg wind RECs on behalf of customers.

15 Page of 0 Q. SINCE THE WINDSOURCE PROGRAM IS SOURCED FROM THE COMPANY S RENEWABLE PORTFOLIO, HOW WILL THE COMPANY ACCOUNT FOR THE FACT THAT CUSTOMERS PURCHASING 00 PERCENT OF THEIR ENERGY FROM WINDSOURCE ARE PURCHASING ENERGY FROM A PORTFOLIO OF RENEWABLE ENERGY REQUIRED FOR THE COLORADO RES? A. The Company s renewable portfolio tracks RECs produced by various sources. Therefore, when submitting RECs for certification through Green-e the Company can provide only RECs associated with non-dg wind to ensure that other compliance RECs are not retired on behalf of Windsource customers. Q. WILL THE PROPOSED CHANGE IN THE WINDSOURCE PRICING METHODOLOGY, AS SPONSORED BY MS. KLEMM, HAVE ANY EFFECT ON THE RETIREMENT OF RECS OR THE COMPANY S COMPLIANCE? A. The Company anticipates that the change in pricing, if approved, will result in an increase in participation in the Windsource program and therefore an increase in non-dg wind REC retirement. However, this forecasted increase in retirements should not affect the Company s RES compliance position.

16 Page of Q. HAVE THE WINDSOURCE CUSTOMERS BEEN NOTIFIED THAT A PORTION OF THE RECS ASSOCIATED WITH WINDSOURCE SALES WILL BE RETIRED FOR RES COMPLIANCE? A. Yes. In the Summary of Prices, Terms and Conditions on the Company s website, the Company explains this special retirement provision for 00 percent subscription. There is also an annual notification provided in the Windsource customer bill that includes the product content label approved by Green-e. Windsource_for_Residences_-_Pricing_Terms_and_Conditions_-_CO

17 Page of 0 0 V. WESTERN RENEWABLE ENERGY GENERATION INFORMATION SYSTEM (WREGIS Q. CAN YOU PLEASE PROVIDE MORE BACKGROUND ON WREGIS? A. WREGIS is an independent, renewable energy registry and credit tracking system for electricity generation within the western states, including Colorado. WREGIS was developed through a collaborative effort between the Western Governors Association, the Western Regional Air Partnership and the California Energy Commission. WREGIS is operated by the Western Electricity Coordinating Council, of which Public Service is a member. Q. IS PARTICIPATION IN WREGIS MANDATORY? A. Yes. Pursuant to Commission Rule (j, effective December 0, 00, all renewable energy resources located in the region covered by the Western Electricity Coordinating Council (WECC that generate RECs used by the Company for RES compliance are to be registered in WREGIS and the RECs from these resources are to be recorded in WREGIS, with the exception for small retail DG. Q. ARE THERE COSTS ASSOCIATED WITH PARTICIPATION IN WREGIS? A. Yes, Public Service will incur costs for participating in WREGIS. WREGIS charges an annual account holder fee of $. In addition, WREGIS charges a fee when a renewable energy credit or certificate is issued, transferred, or retired. The WREGIS issuance and transfer fee is $0.00 per certificate. The fee for retiring a REC is $0.0 per certificate. The Company anticipates its

18 Page of expenses associated with participation in WREGIS, net of wholesale costs, will be approximately $00,000 to $0,000 each year. Q. ARE ANY ADDITIONAL REC TRACKING EXPENSES EXPECTED? A. No. Q. HOW IS PUBLIC SERVICE PLANNING TO RETIRE RECS FOR COMPLIANCE WITH THE RES? A. For compliance year 0-0, Public Service plans to retire non-dg and Wholesale-DG RECs for RES compliance in WREGIS. All generation from Retail-DG systems smaller than MW will continue to be tracked through the Solar*Rewards system and the RECs will be reported and retired in the REC Tracking System for all vintages. Q. DOES THIS CONCLUDE YOUR TESTIMONY? A. Yes, it does.

19 Page of Statement of Qualifications, Jeffrey C. Haskins September 0 Present - Renewable Energy Portfolio Manager, Xcel Energy Manage the group responsible for the overall management of Xcel Energy s renewable energy portfolio and the Companies compliance with Renewable Portfolio Standards. Administrator of Xcel Energy s accounts in the WREGIS, M-RETs and ERCOT REC registries and the Company s internal REC tracking system. July 00 to September 0 - Trading Analytics Manager, Xcel Energy Managed the team responsible for the optimal commitment of the Company s generation assets on a daily basis. Maintained economic as well as reliable operation of the Company s power system. Lead modelling efforts of day to day production cost modelling platform. Managed the team responsible for executing demand response, plant overhaul coordination, generation offers and load bids into ISO s while ensuring adequate operating reserves were available. June 00 to July 00 - Trading Analyst, Xcel Energy Responsible for optimizing the generation portfolio using production cost modelling. Coordinate and submit energy offers to ISO s. Monitor and report wholesale market pricing information. Education Bachelor of Science in Applied Science, Black Hills State University