PUC DOCKET NO. BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS APPLICATION OF TEXAS-NEW MEXICO POWER COMPANY FOR AUTHORITY TO CHANGE RATES

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 EMMANUEL J. LOPEZ ON BEHALF OF TEXAS-NEW MEXICO POWER COMPANY MAY 0, 0

TABLE OF CONTENTS I. INTRODUCTION AND QUALIFICATIONS... II. ACCOUNTING FOR TNMP S ADVANCED METERING SYSTEM COST OF SERVICE AND RATE BASE... a) Cost of Service... b) Customer Benefit Savings... c) O&M Expenses... d) Depreciation and Amortization Expense... e) Return on Rate Base... f) Taxes... g) Rate Base... h) Electric Plant... i) Regulatory Assets/Liabilities... j) Accumulated Deferred Federal Income Taxes... III. ACCOUNTING FOR AMS SURCHARGE REVENUES... a) Billed Revenues... IV. DIFFERENCES BETWEEN THE AMS SURCHARGE MODEL AND ACTUALS... V. CUSTOMER BENEFIT SAVINGS... 0 a) Property Tax Savings... 0 b) Meter Reader Savings... c) Meter Tampering... VI. DEPRECIATION EXPENSE... a) Meter Depreciation... b) Network Depreciation... c) IT Depreciation... d) Removal Costs And Salvage... VII. REGULATORY ASSETS... VIII. REGULATORY ASSET AMORTIZATION... 0 IX. RETURN ON INVESTED CAPITAL... a) Interest Expense... b) Return on Equity... X. PROPERTY TAX... i

XI. SEVERANCE LIABILITY... XII. OVER- AND UNDER- REGULATORY LIABILITY... XIII. CONCLUSION... 0 ii

EXHIBITS EXHIBIT EJL- EDUCATIONAL BACKGROUND AND EXPERIENCE EXHIBIT EJL- MONTHLY AMS BREAKOUT Co-Sponsor of following exhibit included in Annual Report of AMS Costs and Savings Detail Cumulative as of March, 0. Exhibit SRW - AMS Reconciliation Report iii

0 0 I. INTRODUCTION AND QUALIFICATIONS Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND PLACE OF EMPLOYMENT. A. My name is Emmanuel J. Lopez, and I am employed by PNMR Services Company ( PNMR Services ), a wholly owned subsidiary of PNM Resources, Inc. ( PNM Resources ). My business address is Silver Ave SW, Albuquerque, New Mexico 0. My title is Director Financial Planning within the PNMR Services Financial Planning and Risk Management department. Formerly, I was Manager Texas-New Mexico Power ( TNMP or Company ) Accounting, within the PNMR Services Utility Accounting Department. Q. ON WHOSE BEHALF ARE YOU TESTIFYING? A. I am testifying on behalf of TNMP. Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL EXPERIENCE. A. I have a Bachelor s Degree in Finance from The University of New Mexico. I am a Certified Public Accountant in the State of New Mexico. I have served in my current position for approximately six months. Prior to that, I served as Manager of PNM Utility Accounting for one year and Manager of TNMP Accounting and Internal Reporting for four-plus years in the PNMR Services Utility Accounting Department. Previously, I was Audit Senior for Moss Adams LLP for two years and Accounting Senior for Clifton Gunderson LLP for five years. My professional credentials and experience are summarized in Exhibit EJL- Q. HAVE YOU EVER FILED TESTIMONY IN A REGULATORY PROCEEDING? A. Yes, I submitted pre-filed testimony in Docket No., Application of Texas-New Mexico Power Company to Reconcile AMS Costs. Application of Texas-New Mexico Power Company to Reconcile Advanced Metering System Costs, Docket No. (Mar, 0).

0 0 Q. PLEASE BRIEFLY DESCRIBE THE PNMR SERVICES UTILITY ACCOUNTING DEPARTMENT AND ITS RELATIONSHIP TO TNMP. A. The PNMR Services Utility Accounting Department is responsible for the accounting and reporting of business transactions that are specific to PNM Resources regulated utility businesses, including TNMP. The PNMR Services Utility Accounting Department is responsible for all accounting matters with regard to TNMP including the accounting for retail revenues, operations and maintenance expense, and regulatory matters such as rate riders and regulatory assets and liabilities. Q. WHAT WERE YOUR PRIMARY RESPONSIBILITIES IN YOUR FORMER POSITION IN TNMP ACCOUNTING? A. My primary responsibility was to manage and direct a team of individuals who were responsible for the utility accounting functions specific to TNMP. Q. PLEASE BRIEFLY DESCRIBE YOUR TESTIMONY. A. I will first describe TNMP s accounting treatment of the costs and savings related to TNMP s Advanced Metering System ( AMS ). I will then explain TNMP s AMS reconciliation of customer benefit savings, depreciation expense, regulatory assets and amortization, return on invested capital, property tax, severance liability, and over/under regulatory liability. Q. HAVE YOU PREPARED ANY EXHIBITS? A. Yes. I am sponsoring Exhibits EJL- and EJL- and co-sponsoring certain exhibits in the AMS Reconciliation Report. Each of these exhibits was prepared by me or under my direction and control. The information contained in these exhibits is true and correct to the best of my knowledge and belief. II. ACCOUNTING FOR TNMP S ADVANCED METERING SYSTEM COST OF SERVICE AND RATE BASE 0 Q. WHAT COSTS ARE RECOVERABLE THROUGH THE AMS SURCHARGE? A. The Commission s Substantive Rule regarding advanced metering, Tex. Admin. Code.0(k)() (TAC), provides for an electric utility to recover the reasonable and necessary costs incurred in deploying AMS to residential and

0 0 nonresidential customers, other than those required by Electric Reliability Council of Texas ( ERCOT ) to have an interval data recorder meter, through an AMS surcharge. In Docket No. 0, TNMP received approval of its AMS deployment plan and a surcharge based on estimated costs for deploying AMS within TNMP s service territory ( TNMP s Deployment Plan ). As TNMP witness Stacy R. Whitehurst explains separately, all costs recovered under the surcharge are to be reviewed in reconciliation proceedings, in which costs incurred pursuant to an approved AMS deployment plan are presumed to be reasonable and necessary. In Docket No., the Commission approved the reconciliation of TNMP s AMS expenses incurred from first deployment through August, 0. Those reconciled costs represented a $0,, revenue requirement through August, 0, including return on a $,,00 rate base as stated in Finding of Fact No.. The following represents a list of the categories of expected savings and costs associated with TNMP s Commission approved Deployment Plan, included in TNMP s AMS surcharge, and subject to reconciliation: customer benefit savings, operations and maintenance expenses ( O&M ), depreciation expense, amortization expense, federal income taxes, taxes other than income taxes ( TOTI ), return on invested capital, and carrying charges related to any over/under collection of revenues. Texas-New Mexico Power Company's Request for Approval of Advance Metering System (AMS) Deployment and AMS Surcharge, Docket No. 0 (Jul., 0). Docket No. 0, Finding of Fact No..

0 0 TNMP s AMS-related invested capital consists of: advanced meters, network plant, information technology (IT) hardware and software, regulatory assets and liabilities, and deferred taxes. The net total of this invested capital served as the basis to calculate a return using TNMP s Commission approved weighted average cost of capital ( WACC ). I will discuss TNMP s WACC in more detail later in my testimony. Q. HOW DOES TNMP TRACK THE COSTS ASSOCIATED WITH TNMP S AMS DEPLOYMENT PLAN? A. TNMP accounts for its investment in AMS assets and expenses in a manner that allows the Commission to fully review the costs associated with TNMP s Deployment Plan. The AMS capital investment and related accumulated depreciation reserves are specifically recorded through unique accounting codes utilizing the appropriate Federal Energy Regulatory Commission ( FERC ) accounts, sub accounts, and property units. In order to provide the ability to track the different costs associated with TNMP s Deployment Plan from the costs within TNMP s cost of service and recovered through base rates set in Docket No. 0, TNMP has created specific FERC subaccounts to track AMS invested capital, regulatory assets and liabilities for TNMP s deferred ams deployment costs and/or revenues, as well as a specific project code and work orders to track AMS related O&M. Pursuant to TAC.0, all costs recovered through the AMS surcharge are to be reviewed in a reconciliation proceeding. TNMP bills the AMS surcharge on a monthly basis under rates that are based on projected expenditures as established in the Final Order in Docket No. 0 Application of Texas-New Mexico Power Company for Authority to Change Rates, Docket No. 0 (Jan., 0).

0 0 0 ( Final Order ). Variances are inevitable because actual expenditures usually deviate to some degree from projected amounts. For instance, TNMP s surcharge model used in Docket No. 0 (the AMS Surcharge Model ) assumed that approval and initial deployment of meters would take place some months before the Final Order was issued. As a result, such variances will lead to an over-/under-recovery of actual costs through surcharge revenues that were based on the model. In addition, the AMS Surcharge Model was designed to front-load revenues from 0 through February 0 while AMS meters were being deployed. This type of rate design inherently results in an over-recovery during this time period as higher revenues are collected up front while there is less meter depreciation. After this time period, revenues decrease, as nonresidential customers surcharge expired on February 0, 0, and depreciation increases with more meters deployed, flipping the balance to an under collection with the intention to be at zero at the end of the AMS surcharge period. For accounting purposes, the difference between TNMP s AMS surcharge revenue and its allowed revenue requirement must be deferred on the balance sheet throughout the life of the AMS surcharge to appropriately reflect over-/underrecoveries experienced. The accounting methodology discussed above is necessary to ensure that AMS costs and investment are separately tracked, to calculate amounts subject to deferral due to the difference between AMS surcharge revenues and AMSrelated costs, and to keep the Company s books and records in accordance with Generally Accepted Accounting Principles ( GAAP ). Consistent with Finding of Fact No. in the Final Order, TNMP is recording AMS revenues, AMS costs, and AMS savings in a manner that readily allows for the identification, tracking, and reporting of these amounts on a monthly basis. Q. HOW CAN THE COMMISSION BE ASSURED THAT THE COMPANY WILL NOT RECOVER AMS DIRECT AND INDIRECT COSTS THROUGH BOTH THE AMS SURCHARGE AND BASE RATES? A. TNMP made the original application for approval of TNMP s Deployment Plan and surcharge on May, 00. This proceeding was abated in January 0,

0 0 and finally resolved through a unanimous settlement agreement approved by the Commission on July, 0. By March 00, TNMP had deployed all the pilot meters. While the AMS case was proceeding in the summer of 00, TNMP filed a general base rate case on August, 00 using a test year of April, 00 through March, 00. As part of TNMP s general base rate case, TNMP removed the costs and assets associated with TNMP s Deployment Plan for AMS, including pilot costs. TNMP received a final order for its general base rate case in Docket No. 0 on January, 0. The Final Order approves recovery for TNMP s pilot project costs through the surcharge. Therefore, all AMS costs including pilot program costs are recovered through the AMS surcharge and not through base rates. In addition, TNMP received a final order in its Reconciliation of Advanced Metering Costs in Docket No. on March, 0. The final order approved recovery through the surcharge of its reconciled $0,, AMS revenue requirement through August, 0. All AMS costs incurred by TNMP since that date and through March, 0 are to be reconciled in this proceeding. TNMP will account for all AMS costs incurred between April, 0 and the date the rates established in the present case become effective. Those costs will be subject to future reconciliation. Future AMS costs will then be recovered through the base rates to be set here (including operating expenses and AMS rate base), as proposed and explained by Stacy R. Whitehurst. Once base rate treatment of AMS costs is provided for, the surcharge can terminate, as Stacy R. Whitehurst addresses. Q. HAS TNMP INCLUDED COSTS RELATED TO OLD METERS THAT HAVE BEEN REPLACED BY AMS METERS IN THE AMS SURCHARGE? Docket No. 0, Finding of Fact No. ( Consistent with the Stipulation, TNMP's actual AMS pilot program costs of $,,.00 are reasonable and necessary costs incurred in deploying AMS and should be approved for recovery through the AMS surcharges provided for in the Stipulation and Final Order ). $,0, of the pilot program costs were O&M Costs and the remaining were related to capital. The pilot program O&M costs were recorded as a regulatory asset and included in the regulatory asset section of the reconciliation model. The pilot program capital costs are included in the gross plant section of the model.

0 A. No, the old mechanical meters are segregated in the general ledger under a separate FERC subaccount. Consistent with Finding of Fact No. in the Final Order, as the mechanical meters are retired as a result of TNMP s AMS Deployment Plan, the net book value of the retired meters are reclassified as a regulatory asset and amortized at the same rate the meters were being depreciated at the time the settlement in Docket No. 0 was approved. The net book values of the retired meters are collected as a part of base rates. In addition, consistent with Finding of Fact No. in the Final Order, TNMP has assigned 0% of the installation cost for AMS meters as cost of removal of the old mechanical meters, and has applied that amount to the accumulated depreciation of the old meters. This treatment enables TNMP to collect cost of removal of the old meters in base rates and not the AMS surcharge. TNMP has appropriately assigned the other 0% of the installation costs as the cost to install AMS meters which will be reconciled in the AMS filing. a) Cost of Service 0 Q. PLEASE IDENTIFY THE COMPONENTS OF TNMP S AMS COST OF SERVICE THAT HAVE BEEN INCLUDED IN THIS RECONCILIATION. A. The AMS cost of service includes operating costs and return on rate base that are reasonable and necessary to deploy AMS meters. Operating costs include: customer benefit savings, O&M expense, depreciation and amortization expense, federal income taxes, and taxes other than income (TOTI). b) Customer Benefit Savings Q. PLEASE IDENTIFY THE CUSTOMER BENEFIT SAVINGS COMPONENTS OF TNMP S AMS COST OF SERVICE THAT HAVE BEEN INCLUDED IN THIS RECONCILIATION.

A. TNMP has captured the following customer benefit savings components as a reduction to the AMS cost of service: Meter reading savings, Ad valorem taxes associated with the retirement of the old mechanical meters, BTS internal support and associated loads, Product maintenance for systems that are being replaced or eliminated, Reduced purchases of field collection system ( FCS ) hand held devices, and Revenues captured as a result of meter tampering. 0 0 Q. WHICH CUSTOMER BENEFITS SAVINGS WILL YOU BE COVERING IN YOUR TESTIMONY? A. Along with TNMP witness Stacy R. Whitehurst, I will be addressing the meter reading and tampering savings that have been achieved. I will also address the ad valorem tax savings that have been achieved. TNMP witness Barry F. Sullivan will discuss the savings related to BTS internal support, product maintenance for systems being replaced and reduced purchases of field collection system handheld devices. c) O&M Expenses Q. PLEASE DESCRIBE THE AMS O&M EXPENSES THAT ARE A PART OF THE AMS COST OF SERVICE. A. TNMP s AMS cost of service includes those O&M costs that are associated with TNMP s Deployment Plan. These costs include, but are not limited to, the following categories that have been reported in TNMP s prior annual AMS filings: Network Cellular Cost, Product Maintenance, Security Management and Monitoring Tool Maintenance, Low Income Home Monitor reimbursement, Severance payment,

0 0 0 Customer Education, HAN Testing, Security Audits, Labor Production Support, Legal Expenses, SMTP Web Portal, Salary for new personnel, Meter Testing Labor, Pilot retrofit costs, Meter testing assessment, Temporary personnel, and Shipping Charges. Q. WILL YOU BE TESTIFYING ON ANY OF THE O&M EXPENSES? A. No. As Stacy R. Whitehurst identifies in his testimony, other witnesses will cover the reasonableness and necessity of O&M categories. Q. DO YOU HAVE ANY RESPONSIBILITIES ASSOCIATED WITH AMS O&M EXPENSES? A. Yes. As TNMP s former primary accountant and current AMS accounting witness, I am responsible for the accounting and reporting of the AMS related O&M. TNMP has specific work orders assigned to the TAMS000 project to track the O&M categories listed above. All O&M costs related to AMS are recorded to this project. These costs are further verified by responsible parties on a quarterly basis to remove any costs identified as non-ams or add any costs that were not appropriately included. I use these work orders to provide the necessary internal and external reporting that is needed, including determining any over-/under- collections that need to be recorded to TNMP s books. d) Depreciation and Amortization Expense Q. PLEASE PROVIDE A BRIEF DEFINITION OF THE ACCOUNTING FOR TNMP S AMS DEPRECIATION. A. From an accounting perspective, the term "depreciation is defined as a system that distributes the cost of assets and estimated removal costs less net salvage (if any), over the estimated useful life of the assets. The amount allocated to

0 0 0 any one accounting period does not necessarily represent the loss or decrease in value that will occur during that particular period. Thus, depreciation is considered an expense or cost, rather than a loss or decrease in value. The Company records depreciation based on the original cost of all property included in each depreciable plant account. On retirement, the full cost of depreciable property, less the net salvage amount, is charged to the depreciation reserve. Q. PLEASE PROVIDE A BRIEF DEFINITION OF THE ACCOUNTING FOR TNMP S AMS AMORTIZATION. A. Amortization is the gradual elimination of an asset or liability by distributing such amount over a fixed period, over the life of the asset or liability to which it applies, or over the period during which it is anticipated the benefit will be realized. Q. HOW IS DEPRECIATION CALCULATED ON TNMP S AMS ASSETS INCLUDED IN THE AMS SURCHARGE MODEL? A. The plant included in the AMS Surcharge Model is depreciated using a straightline depreciation rate that allows the Company to recover the full value of an asset. For IT and network related assets, the deprecation rate is based on the asset being fully depreciated in five years or 0 months. For meter related assets, the depreciation rate is based on the asset being fully depreciated in seven years or months. The depreciation periods for IT, network, and meter related AMS assets are consistent with Finding of Fact No. in the Final Order. Q. DID TNMP S AMS SURCHARGE MODEL CONTEMPLATE REMOVAL COSTS AND SALVAGE VALUES? A. Yes. TNMP s AMS Surcharge Model used a.0% cost of removal including salvage on AMS Meters. This percentage was applied to each meter as the cost of removal and salvage to determine the annual amount. Q. HOW DO REMOVAL COST AND SALVAGE PROCEEDS AFFECT THE CALCULATION OF DEPRECIATION? 0

A. As part of a depreciation study using actuarial analysis, estimated costs to remove assets from service in the future, offset with the estimated salvage for those assets are included in the depreciation rate in order to recover those costs over the life of the assets. 0 0 Q. WHEN DOES THE BOOK DEPRECIATION OF AMS METERS, NETWORK PLANT, AND IT PLANT BEGIN FOR FINANCIAL REPORTING PURPOSES? A. Depreciation of advanced meters, network plant, and IT assets related to AMS begins the month after assets are placed in service. This practice assumes the assets are placed in service on the last day of each month. According to the FERC Uniform System of Accounts, meters or devices and appurtenances thereto, for use in measuring the electricity delivered to its users, whether actually in service or held as inventory should be recorded in FERC account 0. This account is considered Electric Plant in Service. All assets that are Electric Plant in Service are depreciated. Meters in inventory that have not yet been installed are placed in service upon receipt and acceptance and are depreciated. Q. PLEASE PROVIDE A BRIEF DESCRIPTION OF HOW AMS SURCHARGE RELATED REGULATORY ASSET AMORTIZATION IS CALCULATED. A. The Commission s Final Order approved a deferral and recovery of pilot program and severance expenses as regulatory assets to be recovered by the AMS surcharge. The amortization is calculated by taking the total Commissionapproved deferred costs over the Commission-approved collection period. Q. DID TNMP ACTUALLY RECORD AND AMORTIZE THE PILOT PROGRAM REGULATORY ASSETS? A. Yes. Consistent with Finding of Fact No. in the final order of Docket No., pilot program expenses that relate to O&M of $,0, were set up in a regulatory asset and are being amortized over years consistent with the AMS Surcharge Model. Application of Texas-New Mexico Power Company to Reconcile Advanced Metering System Costs, Docket No., Mar., 0.

0 0 Q. DID TNMP ACTUALLY RECORD AND AMORTIZE THE SEVERANCE REGULATORY ASSETS? A. No. TNMP accounted for severances as O&M expense and not as a regulatory asset. I discuss this in the severance liability section of my testimony. Q. DID THE COMPANY RECORD A REGULATORY ASSET RELATED TO RETIREMENT OF G METERS? A. Yes. TNMP recorded a regulatory asset for the early retirement of G meters approved in Docket No.. This regulatory asset was not included in Docket No., Application of TNMP to Reconcile AMS Costs, as the costs were not yet known and it was not yet recorded. Q. PLEASE DESCRIBE THE REGULATORY ASSET FOR G METER EARLY RETIREMENT IN DOCKET NO.. A. On July, 0, the Commission approved TNMP s deployment of AMS meters. In August 0, TNMP was informed by AT&T that it planned to sunset its G network in 0. On September, 0, TNMP filed an amendment to the commission approved AMS deployment plan that authorized TNMP to remediate its second generation ( G ) wireless telecom network and update to a third generation ( G ) or later equivalent technology wireless network. Upon Commission approval of that amendment in Docket No., TNMP replaced its G meters and booked a regulatory asset for their net book value of $,, in December of 0. This asset is being amortized at the same rate the meters were being depreciated as approved in Docket No. 0. Q. HOW IS THE COMPANY PROPOSING TO TREAT UNDER- /OVER- RECOVERY OF AMS EXPENSES IN THIS AMS RECONCILIATION FILING? A. TNMP is requesting that the remaining AMS revenue requirement and rate base (included the AMS under collection) after March, 0 be moved into TNMP s base rates. Therefore, TNMP is requesting approval of an additional Application of Texas-New Mexico Power Company for Amendment to its Commission-Approved AMS Deployment Plan, Docket No. (Nov., 0).

0 AMS Over / Under Recovery Regulatory Asset that covers the period April, 0 through the effective date of new rates from TNMP s general rate case. This regulatory asset will be included in a final AMS reconciliation by TNMP. e) Return on Rate Base Q. PLEASE EXPLAIN WHAT RETURN ON RATE BASE MEANS. A. The Public Utility Regulatory Act requires the Commission to establish rates that will permit a utility a reasonable opportunity to earn a reasonable return on the utility's used and useful invested capital. In determining the return for a utility, the Commission applies a WACC percentage to the net invested plant balance. The WACC reflects the utility s approved cost of debt and return on equity, and its authorized capital structure. For TNMP these factors were most recently established in Docket No. 0. The AMS Final Order provided for use of the Docket No. 0 WACC in calculating the AMS surcharge (Finding of Fact ). Q. WHAT IS TNMP S WACC? A. The following table reflects the Commission approved WACC for the AMS Surcharge Model and its calculation. Capital Rates WACC Ratio Debt %.%.% Equity % 0.%.% Total 00%.0% 0 f) Taxes Q. PLEASE DESCRIBE THE TYPES OF TAXES THAT ARE INCLUDED IN TNMP S COST OF SERVICE. A. TNMP is required to pay federal income taxes, ad valorem taxes, and Texas Margin tax. These costs that relate to the deployment plan were approved for recovery in the Final Order. Q. PLEASE DESCRIBE THE FEDERAL INCOME TAX INCLUDED IN THE AMS SURCHARGE MODEL.

A. TNMP is required to pay income taxes to the federal government and income tax is an appropriate expense to be collected through the AMS surcharge. The AMS Surcharge Model assumed an effective tax rate of % to be applied on the ROE component of TNMP s WACC. TNMP witness Larry Morris will provide the specific testimony regarding the Federal income taxes associated with the AMS. 0 0 Q. WHAT IS AD VALOREM TAX? A. Ad valorem tax, also known as property tax, is an expense that is required to be paid to certain taxing authorities and is an appropriate expense to be collected through the AMS surcharge. Property tax is based on property in service on December of the prior year at rates set by the specific taxing authorities. Q. PLEASE DESCRIBE TEXAS MARGIN TAX. A. Since TNMP is doing business in Texas, TNMP is subject to this tax, also known as gross margin tax. It is an appropriate expense to be collected through the AMS surcharge. The Texas Comptroller s website further describes this tax. Q. HOW DID TNMP CALCULATE THE TEXAS MARGIN TAX TO BE INCLUDED IN THE AMS SURCHARGE MODEL? A. TNMP used the Margin tax rate of 0.00% at the time of the filing of Docket No. 0 to calculate Margin tax in the AMS Surcharge Model. This rate is the equivalent to applying a.0% rate to 0.0% of total revenues, grossed up for taxes. TNMP applied this rate to the total annual revenue requirement each year in order to calculate the Margin tax in the AMS Surcharge Model. TNMP witness Larry Morris will discuss Margin tax further in his testimony. g) Rate Base Q. PLEASE DEFINE AMS RATE BASE AND THE COSTS THAT HAVE BEEN INCLUDED IN THIS AMS RECONCILIATION FILING. http://comptroller.texas.gov/taxinfo/franchise/.

A. The AMS rate base includes TNMP s investment in AMS-related meters, hardware, software, and other AMS-related assets net of accumulated depreciation and amortization and accumulated deferred income taxes. I will discuss the accounting of the net plant in service and regulatory assets/liabilities. TNMP s witnesses Robert K. Roberts and Barry F. Sullivan will discuss the actual costs and the usefulness of the assets. h) Electric Plant 0 0 Q. PLEASE DESCRIBE HOW TNMP TRACKS AMS RELATED PROPERTY AND ASSETS. A. TNMP accounts for their investment in AMS assets in a manner that allows the Commission to fully review the costs associated with TNMP s Deployment Plan. AMS investment is specifically recorded through the use of unique accounting codes utilizing the appropriate FERC accounts, sub-accounts, and property unit numbers. This tracking provides for the reporting of the book value of AMS assets in order to ensure they are not included in the Company s base rates. Specifically, TNMP has used the following FERC accounts and sub accounts to record AMS related assets: AMS meters (0.), hardware (.), and software (0.). The first three digits represent the FERC account and the following digit represents the sub account. Q. HAS TNMP INCLUDED CONSTRUCTION WORK IN PROGRESS ( CWIP ) IN THE CALCULATION OF RATE BASE? A. No, TNMP has not included CWIP in the calculation of rate base. Q. HOW DOES MONTHLY DEPRECIATION EXPENSE AFFECT RATE BASE? A. As depreciation expense is recorded, the accumulated depreciation reserve is increased. The accumulated depreciation reserve is a decrease to rate base. As I discussed earlier in my testimony, depreciation expenses is designed to allow the Company to recover the full value of an asset. Q. DID THE AMS SURCHARGE MODEL CONTEMPLATE A POTENTIAL OVER- OR UNDER- RECOVERED DEPRECIATION BALANCE CAUSED BY EARLY

A. RETIREMENTS OR CHANGES IN ACTUAL REMOVAL COSTS COMPARED TO THE ESTIMATED REMOVAL COSTS? No, it did not. 0 0 Q. HAS TNMP INCURRED ANY EARLY RETIREMENTS OR CHANGES IN REMOVAL COSTS? A. Yes, TNMP has early retirements of AMS meters with G technology, as discussed in TNMP s witness Robert K. Roberts testimony and approved in Docket No.. TNMP has incurred removal costs and salvage for these meters. TNMP has also retired AMS meters due to normal wear and tear and business activities. i) Regulatory Assets/Liabilities Q. PLEASE DEFINE REGULATORY ASSETS AND LIABILITIES. A. Regulatory assets and regulatory liabilities are creations of regulation. In, the Financial Accounting Standards Board issued SFAS Accounting for the Effects of Certain Types of Regulation (currently Accounting Standard Codification (ASC) 0), which applies to utilities with cost-based rates that are established by the regulator and charged to, and collected from, customers. In accordance with the requirements of ASC 0-0--, the Company recognizes certain costs as regulatory assets that, as a result of rate actions of a regulator, provide reasonable assurance a previously-incurred cost is probable of being recovered in future rates. Q. ARE REGULATORY ASSETS INCLUDED IN TNMP S AMS RATE BASE? A. Yes. Regulatory assets related to the TNMP s pilot program, early retirements of G meters, and the over / under recovery as discussed above, are all included in TNMP s AMS rate base and excluded from base rates. j) Accumulated Deferred Federal Income Taxes Q. PLEASE EXPLAIN ACCUMULATED DEFERRED FEDERAL INCOME TAXES ( ADFIT ).

A. ADFIT represents deferred taxes resulting from timing differences between tax expense recorded in accordance with GAAP and tax expense calculated under the Internal Revenue Code ( IRC ) and is primarily caused by differing depreciation methodologies. If the depreciation period for taxes is shorter than the book deprecation period, the ADFIT balance is treated as a source of cost free capital, and is used to reduce rate base. 0 0 0 Q. HAS TNMP INCLUDED ADFIT AS AN OFFSET TO ITS AMS RATE BASE? A. Yes. TNMP witness Larry Morris will discuss the specifics around the treatment and calculation of ADFIT in regards to TNMP s AMS rate base. Q. DOES TNMP HAVE PROTECTED AND UNPROTECTED AMS EXCESS ADFIT? A. Yes. TNMP has $,, in ADFIT caused by accelerated depreciation of AMS plant in service of which $,, is considered excess ADFIT. TNMP has $0,,00 in ADFIT caused by AMS regulatory assets of which $,0, is considered excess ADFIT. Excess ADFIT is a result of the recent changes in Tax Reform and represents the % difference from the old federal tax rate of % compared to the new federal tax rate of %. ADFIT created by plant in service is considered protected ADFIT and must follow IRS normalization rules. ADFIT created by other book tax differences are considered unprotected. TNMP witness Larry Morris will discuss the specifics around the treatment and calculation of ADFIT in regards to TNMP s AMS rate base. Q. WAS ADFIT INCLUDED IN THE AMS SURCHARGE MODEL? A. Yes, ADFIT was included based on the old % federal tax rate. Q. PLEASE DESCRIBE THE REGULATORY LIABILITY AND/OR ASSET FOR ANY AMS OVER-/UNDER- RECOVERY. A. Consistent with Finding of Fact No. in the Final Order, TNMP established one or more regulatory asset or liability accounts to record the difference between the AMS surcharge revenues and the net revenue requirement. Due to the levelized approach requested in Docket No. 0, TNMP defers the

0 III. difference between the monthly collected AMS surcharge revenues and the actual incurred AMS costs, net of O&M calculated savings plus the allowed return as a regulatory asset or regulatory liability on the accounting records of TNMP. This deferral reflects the timing difference between costs incurred to deploy the AMS meters and the levelized revenue stream set to recover these costs and is intended to be at zero at the end of the AMS surcharge period. This regulatory asset or liability represents the over- or under- recoveries of AMS costs compared to the revenues collected. Consistent with Finding of Fact No. in the Final Order, carrying charges are accrued based on TNMP s pre-tax cost of capital approved in Docket No. 0 as shown in the WACC table above. This interest rate is to remain in effect until TNMP s general rate case. ACCOUNTING FOR AMS SURCHARGE REVENUES a) Billed Revenues 0 0 Q. HOW DOES TNMP TRACK AMS SURCHARGE REVENUE? A. TNMP creates separate sub rates for each class of customer that is billed the AMS surcharge. This sub rate is attached to a parent rate for billing purposes. When TNMP submits the 0_0 invoice to a Retail Electric Provider ( REP ), the 0_0 invoice specifically identifies the charge for each charge type in base rates and all relevant rider charges. To record revenues in the General Ledger, sub rate codes are used to associate a charge with a base rate or a specific rider. Therefore, TNMP can systematically identify the total amount of revenues associated with the AMS surcharge rider compared to other riders like the Energy Efficiency Cost Recovery Factor or base rate revenues. Q. PLEASE PROVIDE THE AMOUNT OF REVENUES COLLECTED THROUGH THE AMS SURCHARGE DURING THE CURRENT RECONCILIATION PERIOD. A. The tables below list the amount of revenues collected by year and the specific customer class that incurred the AMS surcharge. Table AMS Revenues by Year (September, 0 March, 0)

Year Amount 0 $,, 0 $,0,0 0 $,,0 0 $,,0 Grand Total $,0, Table AMS Revenues by Customer Class (September, 0 March, 0) IV. Tariff Class Amount Residential Service $,, Secondary Service < kw $0, Secondary Service > kw $,, Primary $, Transmission Service - Lighting $,0 Grand Total $,0, DIFFERENCES BETWEEN THE AMS SURCHARGE MODEL AND ACTUALS 0 0 Q. PLEASE DESCRIBE THE NUMBER OF AMS METERS PLACED IN SERVICE THAT WERE INCLUDED IN TNMP S AMS SURCHARGE MODEL. A. The AMS Surcharge Model assumed, AMS meters placed in service by December, 0, which represents the end of the deployment period. Q. PLEASE DESCRIBE THE NUMBER OF AMS METERS PLACED IN SERVICE THAT WAS ACTUALLY ACHIEVED BY TNMP. A. TNMP actually placed, AMS meters in service, net of G retirements, by December, 0 as described in the testimony of Robert K. Roberts. Q. DID THE ACTUAL NUMBER OF AMS METERS PLACED INTO SERVICE BY TNMP DIFFER FROM THE AMOUNT INCLUDED IN THE AMS SURCHARGE MODEL? A. Yes, TNMP placed more AMS meters into service than included in the AMS Surcharge Model. When meters are purchased, they are placed into service in the month they are received. This happens even if the meter has not yet been installed, as this signifies the start of the depreciation cycle. The variance is,0 more meters placed into service by March, 0 and is due to two primary factors: ) TNMP experienced higher customer growth than the AMS Surcharge Model contemplated; and ) the AMS Surcharge Model did not

0 0 consider a working inventory of meters to support field operations. The working inventory is further described in the testimony of Robert K. Roberts. V. CUSTOMER BENEFIT SAVINGS a) Property Tax Savings Q. PLEASE DESCRIBE WHAT PROPERTY TAX SAVINGS WERE INCLUDED IN TNMP S AMS SURCHARGE MODEL. A. As a part of TNMP s AMS Deployment Plan, TNMP is removing the existing non-standard meters and installing advanced meters that meet the requirements of TAC.0. Once the existing meters have been removed, the meters are salvaged. In Docket No. 0, the settlement assumed ad valorem taxes associated with the non-standard meters. Since it is assumed that TNMP is recovering ad valorem taxes through base rates and TNMP is no longer being taxed for the non-standard meter property that has been removed and is no longer in service, the AMS Surcharge Model passes these savings to customers by lowering the AMS revenue requirement. Q. PLEASE DESCRIBE THE PROPERTY TAX SAVINGS ASSUMED IN TNMP S AMS SURCHARGE MODEL. A. The AMS Surcharge Model estimated $,0 in property tax savings from September, 0 through the period ending March, 0. Q. WHAT PROPERTY TAX SAVINGS HAS TNMP ACHIEVED? A. TNMP has recorded $, of property tax savings from September, 0 through the period ending March, 0. Q. DID THE ACTUAL PROPERTY TAX SAVINGS CAPTURED BY TNMP DIFFER FROM THE AMOUNT INCLUDED IN THE AMS SURCHARGE MODEL? A. Yes. The actual property tax savings are $,00 higher than assumed in the AMS Surcharge Model. The higher property tax savings is due to more mechanical meters removed than assumed in the AMS Surcharge Model as discussed above and a higher actual property tax rate than assumed in the 0

0 0 surcharge model The AMS surcharge model assumed a property tax rate of 0.% and TNMP s actual property tax rate has been approximately.%. Q. WILL TNMP CONTINUE TO CAPTURE PROPERTY TAX SAVINGS AFTER THE RECONCILIATION PERIOD DEFINED IN THIS PROCEEDING? A. Yes. TNMP will continue to capture property tax savings until TNMP s base rates are set to reflect property taxes on meters after TNMP s AMS deployment. Q. WHAT DO YOU CONCLUDE REGARDING PROPERTY TAX SAVINGS REALIZED BY TNMP? A. TNMP has properly captured the property tax associated with the non-standard meters being replaced with standard meters. Property tax savings were calculated based on the balance of the retired meter regulatory asset at year end of the prior year multiplied by the annual property tax rate for the current year. b) Meter Reader Savings Q. PLEASE DESCRIBE WHAT METER READER SAVINGS WERE INCLUDED IN TNMP S AMS SURCHARGE MODEL. A. As a part of TNMP s Deployment Plan, TNMP is removing the existing nonstandard meters and installing advanced meters that meet the requirements of TAC.0. Once the existing meters have been removed, there is no longer a need to have an employee visit the location on a monthly basis to obtain a meter read for billing purposes. In Docket No. 0, the settlement assumed meter reader savings associated with TNMP s Deployment Plan since TNMP is recovering meter reading expenses through base rates. Q. PLEASE DESCRIBE THE METER READER SAVINGS ASSUMED IN TNMP S AMS SURCHARGE MODEL. For example, the balance of the retired mechanical meter regulatory asset was $,, at December, 0. The 0 property tax rate was.%. The 0 property tax savings included in the AMS revenue requirement was $,.

A. The AMS Surcharge Model estimated $,, from September, 0 through the period ending March, 0. 0 0 Q. WHAT METER READING SAVINGS HAS TNMP ACHIEVED? A. TNMP has achieved $,0, of meter reading savings. Q. DID THE ACTUAL METER READING SAVINGS CAPTURED BY TNMP DIFFER FROM THE AMOUNT INCLUDED IN THE AMS SURCHARGE MODEL? A. Yes. The actual meter reader savings achieved by TNMP was $, higher than the meter reader savings assumed in the AMS Surcharge Model from September, 0 through the period ending March, 0. This is due primarily to lower actual meter reading costs compared to meter reading costs assumed in the AMS Surcharge Model. Q. WILL TNMP CONTINUE TO CAPTURE METER READING SAVINGS AFTER THE RECONCILIATION PERIOD DEFINED IN THIS PROCEEDING? A. Yes. TNMP will continue to capture meter reading savings until TNMP base rates are set to reflect the meter reading expenses after TNMP s AMS deployment. Q. WHAT DO YOU CONCLUDE REGARDING METER READING SAVINGS REALIZED BY TNMP? A. TNMP has properly captured the meter reader savings associated with the nonstandard meters being replaced with standard meters. To determine the monthly meter reading savings to record, TNMP established a monthly baseline using actual meter reading expense for the period of July, 00 through August, 0. This is the month period before the approval of Docket No. 0. The baseline amount was $0,0. The actual monthly meter reading expenses recorded were compared to the monthly baseline. The delta was recorded as the monthly meter reader savings.

0 0 c) Meter Tampering Q. PLEASE DESCRIBE WHAT ADDITIONAL REVENUES ASSOCIATED WITH METER TAMPERING WERE INCLUDED IN TNMP S AMS SURCHARGE MODEL. A. The AMS Surcharge Model did not include incremental revenues associated with additional collection for meter tampering enforcement. Q. WHAT ADDITIONAL METER TAMPERING ENFORCEMENT REVENUES HAS TNMP ACHIEVED? A. TNMP has recorded $, of AMS related meter tampering revenue. Q. DID THE ACTUAL ADDITIONAL METER TAMPERING ENFORCEMENT REVENUES CAPTURED BY TNMP DIFFER FROM THE AMOUNT INCLUDED IN THE AMS SURCHARGE MODEL? A. Yes. The AMS Surcharge Model did not contemplate additional revenues associated with collection of meter tampering enforcement identified through the new meter alarms in the AMS meters. Q. WILL TNMP CONTINUE TO CAPTURE ADDITIONAL METER TAMPERING ENFORCEMENT REVENUES AFTER THE RECONCILIATION PERIOD DEFINED IN THIS PROCEEDING? A. Yes. TNMP will continue to capture additional revenues associated with meter tampering until all incremental monthly O&M expenses associated with fraud investigations are moved into base rates. Q. WHAT DO YOU CONCLUDE REGARDING ADDITIONAL METER TAMPERING ENFORCEMENT REVENUES REALIZED BY TNMP? A. TNMP has recorded actual tampering revenue based on the alarms sent from the meter to TNMP. TNMP has appropriately recorded this revenue to the specific project and work orders used to track AMS revenues and expenses and therefore benefits customers as a reduction to the reconciled AMS revenue requirement.

Q. HAS TNMP PROPERLY CAPTURED THE ADDITIONAL METER TAMPERING ENFORCEMENT REVENUES ASSOCIATED WITH THE NON-STANDARD METERS BEING REPLACED WITH STANDARD METERS? A. Yes. TNMP has recorded all tampering revenue found by AMS meter alarms to the AMS project and work orders. TNMP witness Stacy R. Whitehurst will discuss the calculation of meter saving in his testimony. VI. DEPRECIATION EXPENSE a) Meter Depreciation 0 0 Q. HOW DID TNMP CALCULATE METER DEPRECIATION IN THE AMS SURCHARGE MODEL APPROVED BY THE COMMISSION? A. As discussed above, the Commission s Final Order requires TNMP to depreciate the AMS meters over seven years 0 on a straight-line basis. The meter depreciation for a single meter in the AMS Surcharge Model consists of the meter cost, meter installation costs, project management, taxes, loads, and cost of removal net of any salvage. Total meter depreciation considered in the AMS Surcharge Model from September, 0 through the period ending March, 0 is $,,0. Q. WHAT AMOUNT WAS ACTUALLY RECORDED AS AMS METER DEPRECIATION? A. TNMP has actually recorded $,,0 in AMS meter depreciation from September, 0 through the period ending March, 0. Q. DID THE ACTUAL METER DEPRECIATION INCURRED BY TNMP DIFFER FROM THE AMOUNT INCLUDED IN THE AMS SURCHARGE MODEL? 0 Docket No. 0, Finding of Fact No.. The seven-year depreciation period utilized for the meter investment and related infrastructure costs in TNMP's AMS Surcharge Model is reasonable. The fiveyear depreciation period utilized for information technology and software assets in TNMP's AMS Surcharge Model is reasonable. Docket No. 0, Finding of Fact No.. The meter installation costs included in TNMP's modified AMS Surcharge Model to be recovered through the surcharge are net of a 0% reduction from the total estimated meter installation costs. This reduction reflects the portion of the installation costs that should be allocated to cost of removal for non-ams meters. The cost of removal of the non-ams meters will be charged to accumulated depreciation of these meters, independent of the AMS surcharge.

A. Yes. TNMP has incurred $,,0 more in meter depreciation than assumed in the AMS Surcharge Model from September, 0 through the period ending March, 0. As discussed above, TNMP has placed more meters in service than was included in the AMS Surcharge Model due to higher customer growth and higher working inventory of meters to support field operations, which has caused actual depreciation to be higher than what was assumed in the AMS Surcharge Model. 0 0 Q. WAS THE ACTUAL METER DEPRECIATION INCURRED BY TNMP REASONABLE AND NECESSARY? A. Yes. TNMP properly accounted for the meter depreciation and the associated costs consistent with the AMS Surcharge Model and the Final Order. Therefore, these costs are reasonable and necessary. Q. WILL TNMP CONTINUE TO INCUR METER DEPRECIATION AFTER THE RECONCILIATION PERIOD DEFINED IN THIS PROCEEDING? A. Yes. TNMP will continue to incur meter depreciation that will be recovered under the AMS Surcharge until TNMP s base rates are set to recover AMS meter depreciation. b) Network Depreciation Q. HOW DID TNMP CALCULATE NETWORK DEPRECIATION IN THE AMS SURCHARGE MODEL APPROVED BY THE COMMISSION? A. TNMP s Deployment Plan included network hardware, such as meter testing equipment, meter security hardware, and network testing equipment. The AMS Surcharge Model assumed depreciation of network assets over seven years. Total network depreciation considered in the AMS Surcharge Model from September, 0 through the period ending March, 0 is $,0. Q. WHAT AMOUNT DID TNMP ACTUALLY RECORD AS AMS NETWORK DEPRECIATION? A. TNMP has actually recorded $, in AMS network depreciation from September, 0 through the period ending March, 0.

0 0 0 Q. DID THE ACTUAL NETWORK DEPRECIATION INCURRED BY TNMP DIFFER FROM THE AMOUNT INCLUDED IN THE AMS SURCHARGE MODEL? A. Yes. TNMP has recorded $, more in network depreciation than assumed in the AMS Surcharge Model from September, 0 through the period ending March, 0. Although TNMP has slightly less network plant than assumed in the AMS Surcharge model, TNMP has higher network depreciation from September, 0 through the period ending March, 0 due to later in-service dates. TNMP witness Robert K. Roberts discusses the costs associated with AMS Network assets. Q. WAS THE ACTUAL NETWORK DEPRECIATION INCURRED BY TNMP REASONABLE AND NECESSARY? A. Yes. The Commission approved recovery of network related assets for TNMP s AMS Deployment Plan, and TNMP has recorded the appropriate depreciation based on the five year requirement in the Final Order. Therefore, the network depreciation incurred by TNMP was reasonable and necessary. Q. WILL TNMP CONTINUE TO INCUR NETWORK DEPRECIATION AFTER THE RECONCILIATION PERIOD DEFINED IN THIS PROCEEDING? A. Yes. TNMP will continue to incur network related depreciation that will be recovered under the AMS Surcharge until TNMP s base rates are set to recover AMS network depreciation or until the assets have been full depreciated. c) IT Depreciation Q. HOW DID TNMP CALCULATE THE SOFTWARE DEPRECIATION IN THE AMS SURCHARGE MODEL APPROVED BY THE COMMISSION? A. TNMP s Deployment Plan included Information Technology changes, which included both hardware and software. TNMP witnesses Robert K. Roberts and Barry F. Sullivan discuss the costs of the Information Technology assets and the associated implementation costs. The Commission s Final Order requires TNMP to depreciate the IT software and related costs over five years. Total IT depreciation considered in the AMS Surcharge Model from September, 0 through the period ending March, 0 is $,,.

0 0 Q. WHAT AMOUNT DID TNMP ACTUALLY RECORD AS AMS IT DEPRECIATION? A. TNMP has actually recorded $,0, in AMS IT depreciation from September, 0 through the period ending March, 0. Q. DID THE ACTUAL IT DEPRECIATION INCURRED BY TNMP DIFFER FROM THE AMOUNT INCLUDED IN THE AMS SURCHARGE MODEL? A. Yes. TNMP has recorded $,0,0 more in IT depreciation than was assumed in the AMS Surcharge Model from September, 0 through the period ending March, 0. The delta is due to higher actual plant in service, including the Outage Management System, and later in service dates for IT plant than the Model had anticipated. TNMP witnesses Robert K. Roberts and Barry F. Sullivan discuss the timing of placing the actual IT related plant into service, the delta in forecasting the costs, and additional costs not included in the AMS Surcharge Model, such as the Outage Management System. Q. WAS THE ACTUAL IT DEPRECIATION INCURRED BY TNMP REASONABLE AND NECESSARY? A. Yes, the IT Depreciation was reasonable and necessary. The Commission approved recovery of IT related assets for TNMP s AMS Deployment Plan, and TNMP has recorded the appropriate depreciation based on the five year requirement in the Final Order. Q. WILL TNMP CONTINUE TO INCUR IT DEPRECIATION AFTER THE RECONCILIATION PERIOD DEFINED IN THIS PROCEEDING? A. TNMP will continue to incur IT depreciation until TNMP s base rates are set to recover AMS IT depreciation or the assets are fully depreciated. Costs incurred between April, 0 and the effective date of new base rates will be recorded to AMS expenses and included in the final AMS reconciliation.

0 0 0 d) Removal Costs And Salvage Q. CAN YOU EXPLAIN THE EXPENSE INCURRED BY REMOVAL COSTS AND SALVAGE FOR AMS METERS? A. Removal costs are expenses incurred associated with the removal of the advanced meter. The salvage value is the value received for the advanced meter at the time the meter is retired. The net salvage value is the salvage value of the advanced meter at the time the meter is retired less the cost of removal. A utility may receive some compensation for the retired asset if the asset can be sold or recycled. In some circumstances, the asset cannot be sold or recycled, and a utility may have to pay a disposal fee. Q. HOW DID TNMP CALCULATE THE REMOVAL COSTS AND SALVAGE IN THE AMS SURCHARGE MODEL APPROVED BY THE COMMISSION? A. The AMS Surcharge Model assumed.0% of the AMS meter installation cost to determine the removal and salvage value for AMS meters. Before applying the.0%, the AMS Surcharge Model excluded 0.0% of the installation cost of the AMS meter as this amount was attributed to the old mechanical meter removal. Total removal and salvage considered in the AMS Surcharge Model from September, 0 through the period ending March, 0 is $,. Q. WHAT AMOUNT DID TNMP ACTUALLY RECORD FOR REMOVAL COSTS AND SALVAGE? A. TNMP has actually recorded $, in AMS removal costs and salvage from September, 0 through the period ending March, 0. Q. DID THE ACTUAL REMOVAL COSTS AND SALVAGE RECORDED BY TNMP DIFFER FROM THE AMOUNT INCLUDED IN THE AMS SURCHARGE MODEL? A. Yes. TNMP has recorded $, less removal costs and salvage than assumed in the AMS Surcharge Model from September, 0 through the period ending March, 0. The actual removal costs and salvage for the advanced meters is.0% of the total AMS meter depreciation recorded from September, 0 through the period ending March, 0. Although AMS