Dff I E - Texas

70 Electric Transinission Cooley SR 1,220,877 27

71 Electric Transinission Cooley SR 43,301 17

72 Electnc Transmission Cooley OT (2,414 90)

73 Electnc Transmission Cooley OT 22,733 46

74 Electric Transmission Cooley RE 51 25

£69 .

10 1

61' a

ud

- t

1111

Southwestern Public Service Company

Transmission Capital Additions for April 1, 2019 through June 30, 2019

A

Line

Additions to Plant-in-Service

Total Affiliate

No. Asset Class Witness Project Category

(Apr. 2019 - Jun. Charges (Included

in Column D) WBS Level 1 Project Group Name and Description

2019)

SPS Line Capacity - This project surveyed and verified the line ratings of the SPS transmission system for lines above 100-kV This project is a required response to a North Amencan Electnc Reliability Corporation ("NERC") Facility Ratings Alert, issued October 7, 2010 and updated on November 30, 2010, requinng transmission owners to venfy that transmission line ratings are based on actual field conditions and, if not, perform necessary activities to base ratings on actual field conditions The survey was done using Light Detection And Ranging ("LIDAR") technology that uses a laser to make highly accurate distance measurements This project provided for the survey work and any mitigations that were needed to raise the facility capacity ratings if the field results were less than expected

SPS Major Line Refurbishment - This project refurbished various 230-kV lines m the SPS systein.

SPS Sub Communication Network Group 1- These projects provided for the construction of a fiber optics communication infrastructure within the SPS region The first leg of a multi-year effort will start in the Amanllo area by mstalling Optical Ground Wire ("OPGW") in the static position on selected transmission lines to create a redundant fiber optic communication ring with access to the Amarillo Transmission Operations Center This nng provides redundant protection paths for the line sections on which the OPGW is installed as well as provides redundant paths for the Supervisory Control And Data Acquisition ("SCADA") system

SPS Sub Communication Network Group 2- These projects provided for the construction of a fiber optics communication infrastructure withm the SPS region This second leg is the continuation of a multi-year effort in the Amanllo area for installing Optical Ground Wire ("OPGW") in the static position on selected transmission lines to create a redundant fiber optic communication ring with access to the Amarillo Transinission Operations Center This nng provides redundant protection paths for the line sections on which the OPGW is installed as well as provides redundant paths for the Supervisory Control And Data Acquisition ("SCADA") system

STEP Newhart Interchange - This project constructed a new 230/115-kV interchange and substation with associated 115-kV transmission lines near Hart, Texas The project upgraded the transmission system in this area and relieved high transmission loadings on the central part of the SPS transmission system in Castro, Parmer, Swisher, Bailey, Lamb and Hale counties SPP issued SPS a NTC for this project

E -11

11-D

ff I n

otut

iaM

W



A

Line


Total Affiliate




2019)

£6

9 Jo

Z61

7 agd

- V

UN

75 Electric Transmission Cooley RE 6,690 00

76 Electric Transmission Cooley RE 32,500 00

77 Electric Transinission Cooley GI 2,203,625 00

78 Electnc Transmission Cooley EC/TI 466 28

79 Electnc Transmission Cooley RE 209,736 54

80 Electnc Transmission Cooley SR 206,43352

8 l Electric Transmission Cooley RE 500 00

sundown-amoco switch 230kV terminals- This project upgraded the 230-kV Sundown and Amoco station line tennmals and increased the transmission line clearance of the 230-kV line from Amoco to Sundown to provide a summer emergency rating of 547 MVA for this line segment The system limitation caused by this line was identified in SPP's 2016 Near Term study SPP issued SPS a NTC for this project

Tierra Blanca 115kV Substation - This project installed a new 115-kV switching station named Tierra Blanca located approximately one-half mile south of Deaf Smith County Interchange and replaced the relay packages on the remote end line terminals of Deaf Smith Interchange, Hereford Interchange, Northeast Hereford Substation, Castro County Interchange and Canyon West Substation This switching station mitigates thermal and voltage issues for certain contingencies in the Hereford area

Tuco Intg 345/230kV Auto #1 upgrade- This project upgraded the 345/230-kV transformer at TUCO Interchange This project was one of the shared network upgrades required for the connection of generation projects approved by SPP in their DISIS 2014-002 study

TUCO Mooreland (Woodward)- This project constructed a single-circuit 345-kV transmission line between the TUCO Substation, near Lubbock, Texas, and Oklahoma Gas & Electnc's ("OG&E") Woodward Substation near Woodward, Oklahoma SPS constructed the line between the TUCO Substation and OG&E's Border Substation near the Texas and Oklahoma border and OG&E constructed the line from the Border Substation to the Woodward Substation The Project was identified in the SPP's Balanced Portfolio Econoimc Studies SPP issued SPS a NTC for this project.

TUCO S 230 115 Xfmr Upgrade - This project replaced the existing 230/115-kV, 250 MVA circuit 1 autotransfonner at TUCO Substation with a new 284 MVA autotransfonner This project was needed to achieve a minimum einergency rating of 273 MVA for both the circuit 1 and circuit 2, 230/I15-kV autotransfonners at TUCO Substation SPP issued SPS a NTC for this project

Unserviceable - Relays - SPS - This project replaced relays detennmed to be unserviceable dunng maintenance or testing activities

W26 Byrd Tap-Cooper Reconductor- This project rebuilt the 4.9-mile, 115-kV line from Byrd Substation Tap to Cooper Ranch Substation to achieve a minimum suminer emergency ratmg of 166 MVA to address regional reliability issues SPP issued SPS a NTC for this project

W-26 Cooper Ranch-Oil Ctr wreck out rebuild - This project rebuilt the 3 5-mile, 115-kV line froin Cooper Ranch Substation to Oil Center Substation to achieve a minimum summer emergency rating of 163 MVA to address regional reliability issues SPP issued SPS a NTC for this project

W26 Reconductor Cunningham-Monument Tap- This project rebuilt the 6 5-mile, 115-kV line from Cunningham Generation Plant to Monument Substation Tap to achieve a rnmimum summer emergency rating of 184 MVA to address regional rehability issues SPP issued SPS a NTC for this project

W40 Reconductor Canyon West-Deaf Smith - This project wrecked out and rebuilt 26 miles of 115-kV transmission line mnning from Canyon West Substation to Deaf Simth Interchange This project was needed to eliminate the overloading of this segment during certain system conditions SPP issued SPS a NTC for this project

W77 Canyon East Tap to Arrowhead - This project rebuilt 115-kV line W77 from Canyon East tap to Arrowhead substation to provide a higher line capacity. SPP issued SPS a NTC for this project

W77 T75 Reconductor Arrowhead to Randall - This project rebuilt approxiinately 3 5 miles of double-circuit I 15-kV transmission line, W77 (Canyon-West to Randall) and T-75 (Osage to Amanllo South) with phase conductors with a minimum of 240 MVA Summer Emergency rating. This project mitigates the overload of the Randall—Canyon East 115-kV line for vanous outages like the I3ushland Interchange to Deaf Smith County Interchange 230-kV SPP issued SPS a NTC for this project

Western St Sub (TAM) - This project installed a 28 MVA, 115/13 2-kV distnbution substation named Westem Street located in Amanllo, Texas This substation was needed to serve new load in the area and to provide contingency back-up capacity for the other distnbution substations m the area

Yoakum Intg. 230/115 Transformer Upgrades- This project replaced the two existing 230/115-kV, 150 MVA autotransfonners at Yoakum County Interchange with two new 250 MVA transfonners This project was needed to prevent the overloading of one of the 150 MVA transformers for the contingency of the other 150 MVA transformer being unavailable SPP issued SPS a NTC for this project

Z66 Booker/Wade Conversion- This project removed the existing 69-kV line Z-66 (Penyton to Booker) and replaced it with a new 115-kV transmission line It also converted the existing Wade and Booker substations to I15-kV operation This project mitigated low voltage and overload conditions due to a Hrtchland-Oclultree 230-kV line outage and allows for future load growth in the area The new source for these substations is the Ochiltree Substation 115-kV bus

E-N

-N-D

ff w

ounp

elw


Transmission Capital Additions for April I, 2019 through June 30, 2019

A

Line


Total Affiliate



. in Column D)

WBS Level 1 Project Group Name and Description

2019)

£69. 10

£61

7 a2 g

d -

t ?

RI

82 Electric Transmission

83 Electric Transmission

Cooley

Cooley

RE

RE

500.00

100,000 00



86 Electric Transmission Cooley RE 3,870,272 30

87 Electnc Transmission Cooley LI 35,000 00

88 Electric Transmission Cooley RE 3,290,947 76

89 Electric Transmission Cooley RE 354,659.95

Chevron South Eddy Fields Load Addition- This project installed a three-way 115-kV switch on transmission lme W-87 west of China Draw substation to provide a new 115-kV service point for a new substation owned by Chevron

Deaf Smith 230kV Breaker Add - This project created a nng bus on the 230-kV side of the Deaf Smith Substation

Eddy County Dbl Bus Dbl Brker 230kV- This project reconfigured the existing Eddy County Interchange 230-kV bus from a inain and transfer bus design to a double bus-double breaker arrangement This project was required to ineet long-tenn firm transmission service requests in the SPP Aggregate Facility Study SPP-20 I3-AG3-AFS-6 SPP issued SPS a NTC for this project

ELR - Relay - SPS - The term "ELR" stands for End of Life Replacement. This project replaced protective relays that had reached the end of their useful life

Facility Upgrade Ancillary Equip - This project provided for the replacement of failing switches, junipers and other ancillaiy equipment

Fault Recorders - SPS - This project installed fault recorders for disturbance monitonng at substations

General Furniture - This project is for purchasing furniture, typically a desk and chairs, for control houses located in substations

GSEC GB NP Howard-Miami - This project rebuilt the existing 69-kV line with a new line using larger conductor and insulated for 115-kV in preparation for future conversion to 115-kV operation SPP issued SPS a NTC for this project

Ink Basin Substation - This project constnicted a new 230/1 I5-kV, three breaker ring bus interchange in the south-central part of Yoakum County, Texas Existing transmission circuits I 15-kV V80 and 230-kV K93 were routed in to and out of the new interchange A new 230/I15-kV, 250 MVA, transformer provides a new source of power for the 115-kV SPP issued SPS a NTC for this project

Interconnection Milwaukee - This project installed the new SPS Quincy Switching Station to provide 115-kV service to South Plains Electric Cooperative to serve new load from thier new Milwaukee Substation

Interconnection XTO Mahoney - This project installed the new Mahoney Switchmg Station to provide a new 230-kV service point to XTO

Lynn Co. 115/69 Xfmr #1 Upgrade - This project replaced the 40 MVA, 115/69-kV transformer at Lynn County substation with a 84 MVA umt. This project was needed to address the overload of the Lynn County Interchange 115/69-kV circuit I transformer for the loss of Lynn County Interchange 115/69-kV circuit 2 transformer. SPP issued SPS a NTC for this project

E-11

11-3

ff lu

ouni

oullY



A

Line


Total Affiliate




2019)

£6

9 Jo

1761

7 au

cl

90 Electric Transmission Total

$ 160,109,222.79 $ 2,772,446.22

91 Electnc General Plant Cooley LI 17,32007

92 Electnc General Plant Cooley RE 282,62136

93 Electric General Plant Cooley RE 99,108 33

94 Electnc General Plant Cooley SR 126,185 66

95 Electric General Plant Cooley SR 283,005 94

96 Electric General Plant Cooley OT 0 45

97 Electric General Plant Cooley OT 57 70

98 Electnc General Plant Cooley RE 91,199 91


100 Elecinc General Plant Cooley LI 406,056 57

101 Electric General Plant Cooley LI 50,000 00

102 Electnc General Plant Cooley RE 93,10277



105 Electnc General Plant Cooley RE 23 42


107 Electnc General Plant Cooley OT 468,247 45

108 Electric General Plant Cooley LI 1,789,522 53

109 Electnc General Plant Cooley OT 30,000.00

110 Electnc General Plant Cooley SR 24,445 10

£6

9 Jo

561

7 a2 gc

l -

f IR

I



(A) C)

Line


Total Affiliate



in Column D)


2019)

Mustang-Shell CO2 115kV Line - This project constructed a new 115-kV

transmission line between the Mustang and Shell CO2 substations The project was

needed to address overloads in the area SPP issued SPS a NTC for this project

OPIE 2 Kiowa-Road Runner 345kV Conv_PID 30639 - This project replaced the

existing 230/115-kV transfonner at Roadrunner Substation with a new 345/115-kV

transformer, converted the Kiowa to Roadrunner line from 230-kV to 345-kV

operation, and constructed a new 345/115-kV double circuit transmission line between

the Kiowa and Potash Junction substations. The project was needed for reliability

reasons and SPP issued SPS a NTC for the project

OPIE 3 Kiowa-China Draw 345kV_PID 30638 - This project installed new 345/115-

kV transformers at North Loving and China Draw substations It also constructed a

new 345-kV transmission line from Kiowa to North Loving to China Draw substation.

The project was needed for reliability and SPP issued SPS a NTC for this project

OPIE TUCO-Hobbs 345kV_PID 30376 - This project constructs a single-circuit 345-

kV transmission line between the TUCO Substation, near Lubbock, Texas, the

Yoakum Substation in Texas, and the Hobbs Generating Substation near Hobbs, New

Mexico The project was evaluated and identified in the 2013 SPP High Prionty

Incremental Load Study ("HPILS") as needed for reliability to alleviate loading

violations on the underlying network and voltage violations due to insufficient power

supply to network load additions In addition to its reliability benefits, the project was

also identified by SPP as providing significant economic benefits In 2016, SPP

issued its Integrated Transmission Planning Near-Term study which identified the

TUCO to Yoakum portion of the project as needed as soon as 2017 to mitigate voltage

issues in that area SPP issued SPS NTCs for this project

Physical Security - This project installed Physical Secunty Upgrades affecting SPS

substation protection with specific work varymg by substation location, current layout,

and threat history Typical secunty measures included the installation of equipment

such as cameras and motion sensors at substations

RB - Purnell Sub - This project installed a new 115-kV terminal at SPS's XIT

Substation to provide 115-kV service to Rita Blanca Electnc Cooperative to serve new

load from its new Wolves Substation

RTU - EMS Upgrade - SPS - This project replaced remote terminal units ("RTUs")

that were at the end of their useful service life

S&E - SPS Sub - These projects provided for the storm and emergency work orders

that repaired substation facilities damaged by inclement weather and natural disasters.

E-11

1I-D

ff luo

unli o

nV



A

Line

Additions to

Plant-in-Service Total Affiliate


(Apr. 2019 - Jun.

2019)

Ch

i

arges (Included

n Column D)




113 Electric General Plant Cooley OT 144,708 67

11, crci

a, 114 Electric General Plant Cooley RE 72,740 30


VZ) Go4 116 Electnc General Plant Cooley OT 171,568 83





Security Access Control System - This project replaced the existing standard locks on

substation entry gates with locks that use an electronic key to restnct substation access

to authonzed personnel and to meet coinpliance requirements.

seminole intg 230/115kV xfmr #1 & #2 upgrades- This project replaced the two

230/115-kV transformers at Seminole Interchange with two 246/283 MVA units This

project was needed for regional reliability to address the overload of the Seminole

230/115-kV transfonners for the outage of the parallel Seminole 230/115-kV

transformer SPP issued SPS a NTC for this project

SPS Checkpoint Firewalls - This project installed firewall hardware on the fiber

optics cominunications system, which is located on the transmission Imes and

substations These firewall hardware installations were needed to provide data

secunty for the data being transmitted over the fiber optic communication system

SPS Walkemeyer 345 115 280 MVA SUB - This project constructed the new

Carpenter Switching Station (fonnerly Stevens County) which is located on the 345-

kV line from Hitchland Interchange to Finney Switching Station. This project was

needed to address low voltages in the area SPP issued SPS a NTC for this project

Tools - Engineering - This project purchased capital tools for engmeenng purposes,

such as relays and test equipment for commissioning laboratories

Tools COM Substation - These projects purchased capital tools for construction and

maintenance activities

Tools Line Field Ops - This project purchased capital tools for the construction of

capital projects

Tools STAC - This project installed a firewall between the Remote Terminal Units

("RTU") at the Substation Technical Application Center (STAC) and the SPS

Transmission Operations Center to provide required data secunty

Tools System Protection Comm Eng- This project purchased the equipment panels

for the Substation Design, Substation Communications, and System Protection

Engineenng Lab These equipment panels have been used to mount the protective

relaying, communication relaying, power supplies, and metenng equipment used in the

lab These panels and equipment are being used for research and developinent of

advanced communication and protection relaying schemes as well as for event analysis

and troubleshooting of field situations that require engmeenng support

Tools, Training Center - This project purchased capital tools to construct capital

projects and capital tools to be used in the training center.

£-In

i-D

ff lu

ounl

ogliV



A 13

Line


Total Affiliate


(Apr. 2019 - Jun. 2019)

Charges (Included in Column D)


£6

9 Jo

L61

7 32

ed

- 17

MI

121

122

123

Electnc General Plant Cooley OT 454,872 11

Electric General Plant Total $ 5,833,077.21 $ 272,611.20

Grand Total $ 165,942,300.00 $ 3,045,057.43

Transportation - SPS - These projects purchased fleet vehicles for operation in the SPS area. The vehicles Included automobiles, trucks, heavy vehicles such as bucket trucks, high-reach bucket trucks, hole-diggers, and trailers Without these vehicles, crews would not have access to a predictable and reliable method of transport nor have the necessary equipment to perform needed transmission construction work

£-11

11-D

ff I

lloun

lou

lly

Attachment JJC-RR-4 Page 1 of 30

2019 TX Rate Case

Xcel Energy-

TOLK GENERATORS CHANGE OF OPERATION STUDY

Transmission Planning South Xcel Energy Services, Inc.

August 11, 2017

RR 4 - Page 498 of 693 02307


2019 TX Rate Case

Executive Summary Transmission Planning South has performed a system impact study for the limited operations of the Tolk 1 and 2 units only during the summer months. The purpose of this study is

• To determine the system impacts of not operating Tolk units during non-summer months i.e., light load (high wind) and winter peak scenario.

• To determine the benefits of converting existing units to synchronous condenser operation during the winter and spring periods.

The Tolk generators operating assumptions considered for this study are • Between October, 2018 to May, 2019 operate both Tolk units at a partial capacity of

175MW • Between October, 2019 to May, 2020 operate one Tolk unit at partial capacity of

175MW and other unit is shutdown • Starting June 2020 operate both Tolk units only during the summer months

Both steady state and stability analysis were performed to study the system impact. Power flow analysis was performed on the 2012 and 2026 Light Load and Winter peak scenario 0 and 5 models representing the 2017 Southwest Power Pool (SPP) ITPNT Model Series. The stability analysis was performed on 2021 Light Load and Winter peak model representing the 2016 Southwest Power Pool (SPP) MDWG reduced Model Series. Also, to study the impact of high wind scenario a 2021 Light Load scenario 5 model was created with 100% firm wind output and no non-firm wind in the model.

NERC Planning Standard TPL-001-4 P1 single contingency (N-1) events and P3 multiple contingency (loss of generator followed by N-1 345kV and above transmission outage) events for facilities in SPS area were chosen for steady state contingency analysis and the NERC TPL-001-4 P1 events and P2 to P5 EHV events for facilities in SPS area were chosen for stability contingency analysis. NERC TPL-001-4 P1 and P2 to P5 EHV events were primarily chosen since non-consequential load loss or interruption of firm transmission service is not allowed. SPP analyzes the SPS system using many of the same disturbances.

The stability results showed unstable system conditions in 2021 Light Load Scenario 5 model for NERC TPL-001-4 P3 multiple contingency (loss of generator followed by N-1 transmission outage) events due to the high wind penetration and less fossil generation. Refer to Section 4 for the stability analysis results.

The power flow results case showed voltage collapse issues in 2021 Light Load Scenario 5 and 2026 winter peak scenario 5 models for NERC TPL-001-4 P1 single contingency (N-1) and P3 multiple contingency (loss of generator followed by N-1 transmission outage) events due to their high wind penetration and less fossil generation. Refer to Section 4 for the steady state analysis results.

This system impact study performed showed the need to convert one of the Tolk units to synchronous condenser operation immediately and later it is required to convert both the Tolk units to synchronous condenser operation by the mid-2020s to mitigate TPL-001-4 P3 multiple contingency (loss of generator followed by N-1) event issues.

2

RR 4 - Page 499 of 693 02308


2019 TX Rate Case

It is also observed that there is a huge real power deficiency in the SPS area by mid 2020s causing severe steady state issues. Conversion of both the Tolk units to synchronous condenser operation alone cannot mitigate all the transmission system performance issues in later years. New generation installation will greatly improve system performance with real and reactive power capability with the changed operation of the Tolk units.

3

RR 4 - Page 500 of 693 02309


2019 TX Rate Case

Table of Contents 1. Introduction 5

2. Study Methodology 5

3. Study Assumptions 5

4. Results 6

Stability Analysis: 6

Steady-State Analysis: 8

5. Conclusion 17

Appendix A 17

4

RR 4 - Page 501 of 693 02310


2019 TX Rate Case

1. Introduction

Transmission Planning South has performed a system impact study for the limited operations of the Tolk 1 and 2 units only during the summer months.

The generator operating assumptions considered for this study are • Between October, 2018 to May, 2019 operate both Tolk units at a partial capacity of

175MW • Between October, 2019 to May, 2020 operate one Tolk unit at partial capacity of 175MW

and other unit is shutdown • Starting June 2020 operate both Tolk units only during the summer months

The purpose of this study is • To determine the system impacts of not operating Tolk units during non-summer months

i.e., light load (high wind) and winter peak scenario. • To determine the benefits of converting existing units to synchronous condenser operation

during the winter and spring periods.

2. Study Methodology

This study was performed using the Power Technologies, Inc. ("PTI") Power System Simulator for Engineering (PSS/E) program version 33.7.0 and contains a steady-state analysis using AC Contingency Checking (ACCC) with a Fixed Slope Decoupled Newton—Raphson (FDNS) solution. The study was conducted to ensure that current NERC Planning Standards' are fulfilled. As an example, for system intact conditions, bus voltages must be maintained between 0.95 — 1.05 per unit of their nominal value and thermal system intact conditions must not exceed their designated A-rating. For contingencies, the voltages are allowed to deviate between 0.90 — 1.05 per-unit of their nominal value. Additionally, the loading on transmission system equipment cannot exceed 100% of the emergency B-rating.

The existing generators in the SPS area were re-dispatched and no additional or new generators were turned on to compensate for the generation deficiency in the system. The remaining generation was imported from the neighboring area into SPS area.

3. Study Assumptions'

Both steady state and stability analysis were performed to study the system impact. Power flow analysis was performed on the 2012 and 2026 Light Load and Winter peak scenario 0 and 5 models representing the 2017 Southwest Power Pool (SPP) ITPNT Model Series. The stability analysis was performed on 2021 Light Load and Winter peak model representing the 2016 Southwest Power Pool (SPP) MDWG reduced Model Series. Also, to study the impact of high wind scenario a 2021 Light Load scenario 5 model was created with 100% firm wind output and no non-firm wind in the model.

The Tolk generator's operating assumptions considered for this study are • Between October, 2018 to May, 2019 operate both Tolk units at a partial capacity of

175MW • Between October, 2019 to May, 2020 operate one Tolk unit at partial capacity of 175MW

and other unit is shutdown

I Requirement for NERC TPL-001-4 2 Requirement for FAC 002-R1 5

5

RR 4 - Page 502 of 693 02311


2019 TX Rate Case

• Starting June 2020 operate both Tolk units only during the summer months

4. Results

NERC Planning Standard TPL-001-4 P1 single contingency (N-1) events and P3 multiple contingency (loss of generator followed by N-1 345kV and above transmission outage) events for facilities in SPS area were chosen for steady state contingency analysis and all the NERC TPL-001-4 P1 events and P2 to P5 EHV events for facilities in SPS area were chosen for stability contingency analysis. NERC TPL-001-4 P1 and P2 to P5 EHV events were primarily chosen since non-consequential load loss or interruption of firm transmission service is not allowed. SPP analyses the SPS system using many of the same disturbances.

Stability Analysis:

2021 Light Load scenario 5 case showed system instability for NERC TPL-001-4 P3 multiple contingency (loss of generator followed by N-1 345kV and above transmission outage) events due to the high wind penetration and less fossil generation. Below Table 1 shows the stability analysis results.

Table 1: Stability Analysis Results

Year

NERC TPL- 0014

emit

Contingency

1 Contingency 1

Stability Mikis Results

Comments Telt Min and 1 OFF

TOlk unit 1 converted to SynotwonOOS

Condenser; Talk unit 2 OFF

2021L5 P3 Hobbs unit

1&3 Tuco to OKU 345kV (J01) Unstable (Figure 1) Stable

Loss of Hobbs 1 causes Hobbs 3 a

steam unit to turn off (Hobbs 2 is already off in

model)


1&3 Tuco to Border 345kV (111) Unstable (Figure 2) Stable

202115 P3 Hobbs unit

1&3 Crossroads to Eddy 345kV

(J02) Un-damped oscillations

observed Stable


1&3 Tuco to Yoakum 345kV (117)

Un-damped oscillations observed

Stable


1&3 HOBBS to KIOWA (J20)


Stable


1&3 HOBBS to YOAKUM (118)


Stable

2021L5 P3 Hobbs unit 3 Tuco to OKU 345kV (J01) Un-damped oscillations

observed Stable

Figures 1 and 2 to below show the stability plots for unstable events listed in the above Table 1. The plots show angular instability and system collapse for the loss of Hobbs unit 1 and 3 followed by Tuco to OKU 345kV (J01) line and Tuco to Border 345kV (J11) line respectively. Refer to Appendix A for the stability analysis result plots.

6

RR 4 - Page 503 of 693 02312

-50 •

-100

•

-----


2019 TX Rate Case

NO11.1•1•111111.-3111111B111111.1111.1111111.11111111111111111111111-11110111-11.1111•1111.1.11111111111111•111111.1111.11111111111111111,111111111111111111111111111111111111.1111111•111•-111111111-111111“1101111111

Hobbs unit 1&3 : Tuco to OKU 345kV (J01)

0 0 5 1 5 2 2.5 3 3 5 4 E Time (seconds)

1 - ANGL-BLACKHAWK1 113.800 1 . P31_345-230_SPS_HOBBSPLT1&3_J01_21L5_3PH

23 ANGL-MUSTANG_1 113 800 1 P31_345-230_SPS_HOBBSPLT1&3_41_21L5_3PH

28 - ANGL-MUSTANG_3 122 008 1 P31_345-230_SPS_HOBBSPLT1&3 J01_21L5_3PH

1.2 15 ANGL-MADDOX_1 113 800 1 P31_345-230_SPS_H B B SPLT1 &3_J 01_21 L5_3PH

1,7 11 - ANGL-HARRNGTON 1 124.000 1 : P31_345-230_SPS_HOBBSPLT1&3 J01_21L5_3PH

1/1110111,111111MEMS•1111111[111•111111.111111••••••••••••••01111•"11111.1,111.16.11MIRNMIIIMM••11•1111131111111"•••••••••••••“••••••••••••••“=“ 1111111•1111"1 1M 111 ••••••“• 1111 ". 1{ 1111111 • 1•M•J

Figure 1: Angular plots for TPL-001-4 P3 event (Hobbs 1&3 followed by J01)

r • 1=611111•1•111"111•111•11111111.-0111111.111112111”1=•=111-•-..-•11111/111111.11111111111011111111.11116111•111.11111.-.“1-•-.=.-•-•-•111111.11111

Hobbs unit 1&3 : Tuco to Border 345kV (J11)

2 5 7 5 10 12 5 15 17 5 20-

Time (seconds)

• .17 1 ANGL-BLACKHAWK1 113 800 1 - P31_345-230_SPS_HOBBSPLT1&3 J11_21L5_3PH

P31_345-230 SPS_HOBBSPLT183_J11_21L.5_3PH 1.7

23 ANGL-M U STANG_1 113 800 1

28 - NGL-M USTANG_.? 122 600 1 P31 :345-230_SPS_H B B SPLT1&3_J11_21L5_3PH •

G L-MADDO 113 806 1 P31_345-230 SPS_H B EISPLT18.3_J 11_21 L5 3PH

1,7 15 - AN X_1

11 - A N GL-HARRN GTO N 1 124.000 1

P31_245-230_SPS_H OBB SPLT18.3_J 11_21 L5_3PH

Figure 2: : Angular plots for TPL-001-4 P3 event (Hobbs 1&3 followed by J11)

7

RR 4 - Page 504 of 693 02313

•

I -50

▪ -180 -

'• -150

-200


2019 TX Rate Case

Steady-State Analysis:

2021 Light Load scenario 5 case showed voltage collapse for NERC TPL-001-4 P3 multiple contingency (loss of generator followed by N-1) events due to the high wind penetration and less fossil generation. Below Table 2 shows the steady state analysis results for 2021 Light Load scenario 5 model.

Table 2: Steady state analysis results for 2021 Light Load scenario 5 model

_

NW TOL-

0014

event éilRC ngency 2

Staty Analysis Results

d To* Unit/ en 2 OFF Talk unit 1 contorted te Synchronous

ONICienser; To& unit 2 OFF

2021L5 P3 Hobbs unit 3 Tuco to OKU 345kV

(J01)

Solution diverges;

voltage collapse No voltage issues observed

2021L5 P3 Mustang unit 1 Tuco to Yoakum

345kV (117) Solution diverges;

voltage collapse No voltage issues observed

2026 winter peak scenario 5 cases showed voltage for NERC TPL-001-4 P1 single contingency (N-1) and P3 multiple contingency (loss of generator followed by N-1) events due to the high wind penetration and less fossil generation. Below Table 3 shows the steady state analysis results for 2026 winter peak scenario 5 model.

Table 3: Steady state analysis results for 2026 Winter Peak scenario 5 model

Year

MK' Vie 0014 event

Talk tinitt end 2 OFF

lalk unit 1 concerted to Syadvanoes

Condemn Tolk unit 2 OFF

toIun 1

to

2026W5 P3

523461

[BLACKHAWK1

113.800]

526331 [JONES_1 122.000] Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523461

[BLACKHAWK1

113.800]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523461

[BLACKHAWK1 113.800]

527903 [HOBBS_PLT3 118.000] Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523461

[BLACKHAWK1

113.800]

527655 [RSVLT_CC_E 7345.001-

527656 [CROSSROADS 7345.00] CKT 1

Solution diverges,

voltage collapse

No voltage issues

observed

No voltage issues

observed

2026W5 P3 523461

[BLACKHAWK1

113.800]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage issues

observed

2026W5 P3 523462

[BlACKHAWK2 113.800]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523462

[BLACKHAWK2 113.800]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523462

[BLACKHAWK2

113.800]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523462

[BLACKHAWK2

113.800]

527655 [RSVLT_CC_E 7345.00]-

527656 [CROSSROADS 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage issues

observed

2026W5 P3 523462

[BLACKHAWK2

113.800]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage issues

observed

8

RR 4 - Page 505 of 693 02314


2019 TX Rate Case

Year

NERC TP1.- 0014 event

„, .

, Talk WU end 2 ' '

OCR

To& unit1

Syochronous Condensers Yolk '

unit 201*

Tolk tedt 1 and 2

converted to Synchronous Condenser

2026W5 P3

523971

[HARRNGTON1 124.000]

526331 IJONES_1 122.000] Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3

523971

[HARRNGTON1

124.000]


voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3

523971

[HARRNGTON1

124.000]

527163 [MUSTANG_3 122.000] Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523971

[HARRNGTON1

124.000]


voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3

523971

[HARRNGTON1

124.000]

527654 [RSVLT_CC_W 7345.00]-

527655 [RSVLT_CC_E 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523971

[HARRNGTON1

124.000]

527655 [RSVLT_CC_E 7345.00]-

527656 [CROSSROADS 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues observed

No voltage

issues

observed

2026W5 P3

523971

[HARRNGTON1

124.000]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges; voltage collapse

Solution

diverges; voltage

collapse

2026W5 P3

523971


525832 [TLICO_INT 7345.00]-

515458 [BORDER 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523972

[HARRNGTON2

124.000]


voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3

523972

[HARRNGTON2

124.000]


voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3

523972

[HARRNGTON2

124.000]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523972

[HARRNGTON2

124.000]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523972

[HARRNGTON2

124.000]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523972



voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523972

[HARRNGTON2

124.000]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523972

[HARRNGTON2

124.000]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523972

[HARRNGTON2

124.000]

527655 [RSVLT_CC_E 7345.00]-

527656 [CROSSROADS 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523972

[HARRNGTON2

124.000]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3

523972

[HARRNGTON2

124.000]

525832 [TUCO_INT 7345.00]-

515458 [BORDER 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 523973

[HARRNGTON3 526331 [JONES_1 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

9

RR 4 - Page 506 of 693 02315


2019 TX Rate Case

'

Year

NERC TM, 0014 event

• i:

.

AnaR

Tole Witt and a OFF '

To* unit 1 ' comwtod to

nous; talk ,

' To* unit 1 and i

tonverted to *adamants Condenser

124.000]

observed

2026W5 P3

523973

[HARRNGTON3

124.000]


voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3

523973

[HARRNGTON3

124.000]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523973

[HARRNGTON3

124.000]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523973

[HARRNGTON3

124.000]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523973

[HARRNGTON3

124.000]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 523973

[HARRNGTON3

124.000]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523973

[HARRNGTON3

124.000]


voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3

523973

[HARRNGTON3

124.000]

527655 [RSVLT_CC_E 7345.00]-

527656 [CROSSROADS 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

523973

[HARRNGTON3

124.000]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3

523973

[HARRNGTON3

124.000]

525832 [TUCO_INT 7345.00j- 515458 [BORDER 7345.00] CKT 1

Solution diverges;

voltage collapse No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524021 [NICHOLS_1

113.800] 526331 [JONES_1 122.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524021 [NICHOLS_1

113.800] 526332 [JONES_2 122.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524021 [NICHOLS_1

113.800] 527903 [HOBBS_PLT3 118.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524021 [NICHOLS_1

113.800] 525832 [TUCO_INT 7345.00]-

511456 [O.K U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524021 [NICHOLS_1

113.800] 525832 [TUCO_INT 7345.00]-

515458 [BORDER 7345.00] CKT 1 Solution diverges; voltage collapse


No voltage

issues

observed

2026W5 P3 524022 [NICHOLS_2

113.800] 526331 [JONES_1 122.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524022 [NICHOLS_2

113.800] 526332 [JONES_2 122.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524022 [NICHOLS_2

113 800] 527903 [HOBBS_PLT3 118.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524022 [NICHOLS_2

113.800]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524022 [NICHOLS_2 525832 [TUCO_INT 7345.00]- Solution diverges; No voltage issues No voltage

1 o RR 4 - Page 507 of 693 02316


2019 TX Rate Case

Year

NERC TPt- 0014 *vent

Stebilityikturivsts Results

Talk Witt end OFF

Te* unit 1 converted te soithoteatis '

Condenser; Talk unit loff

To& unk 2 and 2

coorerted trS synchronous Condenser

113.800] 515458 [BORDER 7345.00] CKT 1 voltage collapse observed issues

observed

2026W5 P3 524023 [NICHOLS_3

122.000] 526331 [JONES_1 122.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524023 [NICHOLS_3

122.000] 526332 [JONES_2 122.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524023 [NICHOLS_3

122.000] 527903 [HOBBS_PLT3 118.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues observed

2026W5 P3 524023 [NICHOLS_3

122.000]

527655 [RSVLT_CC_E 7345.00]-

527656 [CROSSROADS 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 524023 [NICHOLS_3

122.000]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 524023 [NICHOLS_3

122.000]

525832 [TUCO_INT 7345.001-

515458 [BORDER 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P1 UNIT 1 BUS 526331

[JONES_1 122.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P1 UNIT 1 BUS 526332

[JONES_2 122.000]



No voltage

issues observed

2026W5 P3 527161 [MUSTANG_1

113.800] 526331 [JONES_1 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527161 [MUSTANG_1

113.800] 526332 [JONES_2 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527161 [MUSTANG_1

113.800] 527162 [MUSTANG_2 113.800]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527161 [MUSTANG_1

113.800] 527163 [MUSTANG_3 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues observed

2026W5 P3 527161 [MUSTANG_1

113.800] 527884 [CUNINGHAM4 113.800]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527161 [MUSTANG_1

113.800] 527901 [HOBBS_PLT1 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527161 [MUSTANG_1

113.800] 527902 [HOBBS_PLT2 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527161 [MUSTANG_1

113.800] 527903 [HOBBS_PLT3 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527161 [MUSTANG_1

113.800] 528361 [MADDOX_1 113.800]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues observed

2026W5 P3 527161 [MUSTANG_1

113.800]

526936 [YOAKUM_345 345.00]-

527896 [HOBBS_INT 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527161 [MUSTANG_1

113 800]

527655 [RSVLT_CC_E 7345.00]-

527656 [CROSSROADS 7345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

11

RR 4 - Page 508 of 693 02317


2019 TX Rate Case

MSC

Coattigasc

1 .

....

Tottruniti

conereted tir Synchronous

Condensed:Toth - unk IOW

Tolkunit 2

gonverose to Syndwonous Condenser

observed

2026W5 P3 527161 [MUSTANG_1

113.800]

527656 [CROSSROADS 7345.00]- 527802 [EDDY_CNTY 7345.00] CKT 1

Solution diverges;

voltage collapse No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527161 [MUSTANG_1

113.800)

527896 [HOBBS_INT 7345.001- 527965 [KIOWA 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues observed

2026W5 P3 527161 [MUSTANG_1

113.800]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527161 [MUSTANG_1

113.800] 525832 [TUCO_INT 7345.00]-

515458 [BORDER 7345.00] CKT 1 Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527162 [MUSTANG_2

113.800] 526331 [JONES_1 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527162 [MUSTANG_2

113.800] 526332 [JONES_2 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527162 [MUSTANG_2

113.8001 527161 [MUSTANG_1 113.800]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527162 [MUSTANG_2

113.800] 527163 [MUSTANG_3 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527162 [MUSTANG_2

113.800] 527884 [CUNINGHAM4 113.800]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527162 [MUSTANG_2

113.800] 527901 [HOBBS_PLT1 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage issues

observed

2026W5 P3 527162 [MUSTANG_2

113.800] 527902 [HOBBS_PLT2 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues observed

2026W5 P3 527162 [MUSTANG_2

113.800] 527903 [HOBBS_PLT3 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527162 [MUSTANG_2

113.800] 528361 [MADDOX_1 113.800]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527162 [MUSTANG_2

113.800] 526936 [YOAKUM 345 345.00]-

527896 [HOBBS_INT- 7345.00]CKT 1 Solution diverges; voltage collapse


No voltage issues

observed

2026W5 P3 527162 [MUSTANG_2

113.8001

527655 [RSVLT_CC_E 7345.001-

527656 [CROSSROADS 7345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527162 [MUSTANG_2

113.800]

527656 [CROSSROADS 7345.00]-

527802 [EDDY_CNTY 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527162 [MUSTANG_2

113.800]

527896 [HOBBS_INT 7345.00]-

527965 [KIOWA 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527162 [MUSTANG_2

113.800)

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1 Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

12

RR 4 - Page 509 of 693 02318


2019 TX Rate Case

event

4 cotIngency

a , ,

,

Talc unit 2 ,, converted to sypetwoneuS

Ondensertlettc

nit2OFf "

ink unfit 1

and 2 COneerted %a ,Synehroaons ,

Condenser

2026W5 P3 527162 [MUSTANG_2

113.800]

525832 [TUCO_INT 7345.00]-

515458 [BORDER 7345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000] 523972 [HARRNGTON2 124.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000] 526331 [JONES_1 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527163 [MUSTANG_3

122.000] 526332 [JONES_2 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution diverges;

voltage

collapse

2026W5 P3 527163 [MUSTANG_3

122.000] 527161 [MUSTANG_1 113.800]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000) 527162 [MUSTANG_2 113.800]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000] 527884 [CUNINGHAM4 113.800]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000] 527901 [HOBBS_PLT1 118.000]


Solution diverges;

voltage collapse

No voltage issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000] 527902 [HOBBS_PLT2 118.000)

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000] 527903 [HOBBS_PLT3 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527163 [MUSTANG_3

122.000] 528361 [MADDCA_1 113.800]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527163 IMUSTANG_3

122.000]

525549 [TOLK 7345.00]-527656

[CROSSROADS 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527163 IMUSTANG_3

122.000)

525832 [TUCO_INT 7345.00]-

526936 [YOAKUM_345 345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000] 526936 [YOAKUM_345 345.00)-

527896 [HOBBS_INT 7345.001 CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000]

527655 [RSVLT_CC_E 7345.00]-

527656 [CROSSROADS 7345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000]


Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527163 [MUSTANG_3

122.000]

527896 [HOBBS_INT 7345.00]-

527965 [KIOWA 7345.001 CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527163 [MUSTANG_3

122.0001

525832 [TUCO_INT 7345.001-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527163 [MUSTANG_3

122.000]

525832 [TUCO_INT 7345.00]-

515458 [BORDER 7345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

13

RR 4 - Page 510 of 693 02319


2019 TX Rate Case

Year

„

event

Oantingenty 2 .

Stability Atudysit Resift - ,

sIttik Oen and 2 " OFF

To& unit 1 converted to Synthronous

Condenses To& untt 2OFF

. Tobias* 1 and 2

sowerted to Syndsonoes *indorser

collapse

2026W5 P3

527884

[CUNINGHAM4

113.800]


voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3

527884

[CUNINGHAM4

113.800]


voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3

527884

[CUNINGHAM4

113.800]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

527884

[CUNINGHAM4

113.800]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

527884

[CUNINGHAM4

113.800)


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

527884

[CUNINGHAM4

113.800]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

527884

[CUNINGHAM4

113.800]


voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527884

[CUNINGHAM4

113.800]


voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3

527884

[CUNINGHAM4

113.800]

528361 [MADDOX_1 113.800] Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527884

[CUNINGHAM4

113.800]

527655 [RSVLT_CC_E 7345.00]-

527656 [CROSSROADS 7345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527884

[CUNINGHAM4

113.800]


Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3

527884

[CUNINGHAM4

113.800]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3

527884

[CUNINGHAM4

113.800]

525832 [TUCO_INT 7345.00]-

515458 [BORDER 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527901 [HOBBS_PLT1

118.000] 526331 [JONES_1 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527901 [HOBBS_PLT1

118.000] 526332 [JONES_2 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527901 [HOBBS_PLT1

118.000] 527161 [MUSTANG_1 113.800]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527901 [HOBBS PLT1

118.000] - 527162 [MUSTANG 2 113.800]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527901 [HOBBS_PLT1

118.000] 527163 [MUSTANG 3 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527901 [HOBBS PLT1

118.000] - 527884 [CUNINGHAM4 113.800]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

14

RR 4 - Page 511 of 693 02320


2019 TX Rate Case

year , NERC

TM- 001-4

' event '

TeN oral. convened to Synthnsnons

Condenser; MN . unit 2 OFF

MN oak 1 *Ad 3

eenverted to Synchronous

Condenser

observed

2026W5 P3 527901 [HOBBS_PLT1

118.000] 527902 [HOBBS_PLT2 11.8.000]



No voltage

issues

observed

2026W5 P3 527901 [HOBBS_PLT1

118.000] 527903 [HOBBS_PLT3 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527901 [HOBBS_PLT1

118.000] 528361 [MADDOX_1 113.800]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527901 [HOBBS_PLT1

118.000]

525832 [TUCO_INT 7345.00]-

526936 [YOAKUM_345 345.00] CKT 1

Solution diverges;

voltage collapse


No voltage

issues

observed

2026W5 P3 527901 [HOBBS_PLT1

118.000]

526936 [YOAKUM_345 345.00]-

527896 [HOBBS_INT 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527901 [HOBBS_PLT1

118.000]

527655 [RSVLT_CC_E 7345.00]-

527656 [CROSSROADS 7345.00] CKT 1 Solution diverges; voltage collapse


No voltage

issues

observed

2026W5 P3 527901 [HOBBS_PLT1

118.000]

527656 [CROSSROADS 7345.00]-

527802 [EDDY_CNTY 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527901 [HOBBS_PLT1

118.000]

527896 [HOBBS_INT 7345.00]-

527965 [KIOWA 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527901 [HOBBS_PLT1

118.000]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527901 [HOBBS_PLT1

118.000]

525832 [TUCO_INT 7345.00]-

515458 [BORDER 7345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527902 [HOBBS_PLT2

118.000] 526331 [JONES_1 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges,

voltage

collapse

2026W5 P3 527902 [HOBBS_PLT2

118.0001 526332 [JONES_2 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

2026W5 P3 527902 [HOBBS PLT2

118.000] - 527161 [MUSTANG_1 113.800]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527902 [HOBBS_PLT2

118.000] 527162 [MUSTANG_2 113.800]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527902 [HOBBS_PLT2

118.000] 527163 [MUSTANG_3 122.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues observed

2026W5 P3 527902 [HOBBS PLT2

118.000] - 527884 [CUNINGHAM4 113.800]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 527902 [HOBBS_PLT2

118.000] 527901 [HOBBS_PLT1 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 527902 [HOBBS_PLT2

118.000] 527903 [HOBBS_PLT3 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

Solution

diverges;

voltage

collapse

15

RR 4 - Page 512 of 693 02321


2019 TX Rate Case

Yar

eent

.

Sissbilitykselysts Results

To* taelti amd2 OFf

Talk Sink 1 , consorted to , 4ischronous Omdurman Talk

user /OFF

Tolksugt 1: tad 2

conversed to Synchronous tors:lenses

2026W5 P3 527902 [HOBBS_PLT2

118.000] 528361 [MADDOX_1 113.8001 Solution diverges; voltage collapse


No voltage issues

observed

2026W5 P3 527902 [HOBBS_PLT2

118.000) 525832 [TUCO_INT 7345.001-

526936 [YOAKUM_345 345.00] CKT 1 Solution diverges; voltage collapse


No voltage issues

observed

2026W5 P3 527902 [HOBBS PLT2

118.000] - 526936 [YOAKUM_345 345.001-

527896 [HOBBS_INT 7345.00] CKT 1 Solution diverges; voltage collapse


No voltage issues

observed

2026W5 P3 527902 [HOBBS PLT2

118.000) - 527655 [RSVLT_CC_E 7345.00)-



No voltage issues

observed

2026W5 P3 527902 [HOBBS_PLT2

118.000] 527656 [CROSSROADS 7345.00]-

527802 [EDDY_CNTY 7345.00] CKT 1 Solution diverges; voltage collapse


No voltage issues

observed

2026W5 P3 527902 [HOBBS PLT2

118.000] - 527896 [HOBBS_INT 7345.001-

527965 [KOWA 7345.00] CKT 1 Solution diverges; voltage collapse


No voltage issues

observed

2026W5 P3 527902 [HOBBS_PLT2

118.000] 525832 [TUCO_INT 7345.001-

511456 [0.K.U.-7 345.00) CKT 1 Solution diverges; voltage collapse



2026W5 P3 527902 [HOBBS_PLT2

118.000] 525832 [TUCO_INT 7345.00)-

515458 [BORDER 7345.00] CKT 1 Solution diverges; voltage collapse


No voltage issues

observed

2026W5 P1 UNIT 1 BUS 527903

[HOBBS_PLT3 118.000]



No voltage issues

observed

2026W5 P3 528331 [ASGI10-010

113.800] 526331 [JONES_1 122.000] Solution diverges; voltage collapse


No voltage issues

observed

2026W5 P3 528331 [ASGI10-010

113.800] 526332 [JONES_2 122.000]



No voltage issues

observed

2026W5 P3 528331 [ASGI10-010 113.800)

527903 [HOBBS_PLT3 118.000] Solution diverges; voltage collapse


No voltage issues

observed

2026W5 P3 528331 [ASGI10-010

113.800] 527655 [RSVLT_CC_E 7345.00]-



No voltage issues

observed

2026W5 P3 528331 [ASGI10-010

113.800) 525832 [TUCO_INT 7345.001-

511456 [0.K.U.-7 345.00] CKT 1 Solution diverges; voltage collapse


No voltage issues

observed

2026W5 P3 528361 [MADDOX_1

113.800] 526331 [JONES_1 122.000]



No voltage issues

observed

2026W5 P3 528361 [MADDOX_1

113.800] 526332 [JONES_2 122.000]

Solution diverges, voltage collapse


No voltage issues

observed

2026W5 P3 528361 [MADDOX_1

113.800] 527161 [MUSTANG_1 113.800)



No voltage issues

observed

2026W5 P3 528361 [MADDOX_1

113.800) 527162 [MUSTANG_2 113.800]



No voltage issues

observed

2026W5 P3 528361 [MADDOX_1

113.800) 527163 [MUSTANG_3 122.000]



No voltage issues

observed

2026W5 P3 528361 [MADDOX_1

113.800] 527884 [CUNINGHAM4 113.800]



No voltage issues

observed

16

RR 4 - Page 513 of 693 02322


2019 TX Rate Case

NERC

001-11 event

1

.:

yAfl

' Talk Untel and 2 • OW. : "

Talk unit 1 convert:4Ni to - Synchronous "

Condenser; Toth unk .1 OFF

- MN wit 1 and 2

converted to *chrome Condenser

2026W5 P3 528361 [MADDOX_1

113.800] 527901 [HOBBS_PLT1 118 000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues observed

2026W5 P3 528361 [MADDOX_1

113.800] 527902 [HOBBS_PLT2 118.000]

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 528361 [MADDOX_1

113.800] 527903 [HOBBS_PLT3 118.000]

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues observed

2026W5 P3 528361 [MADDOX_1

113.800]

525832 [TUCO_INT 7345.00]-

526936 [YOAKUM_345 345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P3 528361 [MADDOX_1

113.800]

527655 [RSVLT_CC_E 7345.00]-

527656 [CROSSROADS 7345.00] CKT 1



No voltage

issues

observed

2026W5 P3 528361 [MADDOX_1

113 800]

527656 [CROSSROADS 7345.00]-

527802 [EDDY_CNTY 7345.00] CKT 1

Solution diverges;

voltage collapse


No voltage

issues

observed

2026W5 P3 528361 [MADDOX_1

113.800]

525832 [TUCO_INT 7345.00]-

511456 [0.K.U.-7 345.00] CKT 1

Solution diverges;

voltage collapse

Solution diverges;

voltage collapse

No voltage

issues

observed

2026W5 P3 528361 [MADDOX_1

113.8001

525832 [TUCO_INT 7345.00]-

515458 [BORDER 7345.00] CKT 1

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage

issues

observed

2026W5 P1 Tuco to OKU 345kV

(J01)

Solution diverges;

voltage collapse

No voltage issues

observed

No voltage issues

observed

5. Conclusion

This system impact study performed showed the need to convert one of the Tolk units to synchronous condenser operation immediately and to convert both the Tolk units to synchronous condensers by mid 2020s to mitigate TPL-001-4 P3 multiple contingency (loss of generator followed by N-1 transmission outage) event issues.

It is also observed that there is a huge real power deficiency in SPS area by mid 2020s causing severe steady state issues. Conversion of both the Tolk units to synchronous condenser operation alone cannot mitigate all the transmission system performance issues in later years. New generation installation will greatly improve system performance with real and reactive power capability with the changed operation of the Tolk units.

Appendix A

17

RR 4 - Page 514 of 693 02323

FILE \Out_f4.1as \ P,31,345-210_SPS_HOEIRSPLTlia_J01_21L6_395 out FILE \Out_fa1es\P31_345-230, SPS_HOBBSPLTIA3_J01_2LL5_3PH out

2016 MDWG FINAL wrrs 2015 SERIES MENG FINAL MDWG 2021L WITH !ONG 20211.

FILE \Out_fxlmA5317345-230,_5•PS /1011BSPLTIG3_1101_21L5_3PH-out

1.4 •

t. ,̀20.` :`, 35131:3 -01,E015. .43 Or Z.

, 3 0

c 4..•4.0,

M20.1` 211 1000L-14.1212 PLTO -10 000 11

04 -... :lf. J

22111. 30.1 PICL,0E55 2 122,400 11

0 50000

0 5.0

—

1

-- -............,

1

.222.-

I

.2.2

1

—

—,

—

1

-.

g

—

1

mm 2016 INDWG FD101. WITH 2015 SERIES 11911 FINAL 511244G 2021L WITH MING 2021L

FILE , , \ DutillesT1.7

345-230_SPS_HOBESPLTI&32701_21LS_IPH. out

2:2414 .4 I ' r21 K2. 2.7.2.00 :".. 2 01

55", .L. tv.r; 14D2 . 5, I Ou 4- 4 1

2420,4 204 , 1,7:, Two IN,. 3451 0 4

CIINLY 205 I MI. HIT... 3451 25 COO 4.--11 0 da

—

-.

,—

g

_ !

—

I

I 1 1 1 1 1 1 l

...

a

Li 2016 MDWG FINAL WITH 2015 SERIES NNWG FINAL MDWG 2021L WITH MMHG 20211

"r3.0 , (- 4. 1 trTT •

M,,,Lo 31 MCI. aam.r.,tr 124 04 2"

MILf 41 VOGL -C311C10353442 120 000

4... 4

11

41

.124 10 , Enc,tour 1 124 000 11

0 50000

.- • -0 5000

—

...

—

—

—

,—

-

I

1

I

1

i

....... ... -....

il /

,....

I 1

.521-._. .

...7 .. ,1 ..

....

- .

•••- . i ....

I 1

1 i 1

I ......

I

.. ....

,

I

I i

- -•":1̂ ".

1 1

I

I

E E E

—

-.

—

— g

—

g .-

...-,

1 .....,-..,

—

o

Lg 2016 MDWG FINAL 51110 2015 SERIES MING FINAL M5141 20211 WITH 51.5.10 2021L

•

-auge 44- . rot 33, ,,,,A..3y 3331NIcs 1 411

t 0

4, 4

2112114 1., 0,111 (90 , 411M 2214-0,4 II .53

-25440

CM414 040, Ng ( I, wurrua-ITIN•rmo.c 2200

1 500025

• —• .1 0000n

,....

—

—

—

—

,—

1

1 1 1

.....

g

—

—

g

....,

g 8

_

I .

.

I I --/-

I I 1

7.

flfl

.1 02

I 2

6


2019 TX Rate Case

RR 4 - Page 515 of 693 02324

C=F: ams•wit FILE I.Out_f11esUl5H_345-230._flPS_ROEBSPLIIE3_J01_21L5_3MIŠyCol oop

1.4;44 1 .1412.L plow •Il ro.. •

.14-1414.1011,- .12 61. 0.

4 1444

c. 1114041 ...,

mud, 21, ITIOL-1154000 PL", .11 000 11 • - "..Ao

0 0 am. 114 op,-,,n01 2 122 000 11

—

0 50000

-0 5000

•

1

-

111111 aim

201G MDWG FINAL WITH 2015 SERIES NMI FINAL MDWG 2021L 161111 MEG 2021L

FILE kOuc fsleakP31 345-230,5PS EDEBSPLT143_,701_21L5_3141_Syeal out

S.Al• 2 ' C VA 1411.44. rr":1N1

. 41,

lfr," :..? 12.4..1 Re:

1 4 , 2 1

11114.11 lC1 4 1,147t1 14,0 .7 ..,)

• t D

111005» 205! 1341TG 14140410110 3451

1 0500

4-4 0 .00 0

_ ...

I

I

I 1 1 4 1

I ) i .) ) ) -..., .- — _

.__ _._ — _

--

l

/

)

1 1 ) i i # )

._____ ..--...._ _....

—

_

_

_

-

_ _. ______._

=" --7- —7 -- i

ti 2016 MDWG FINAL WITH 2015 SERIES MMKG FINAL MDWG 2021L WITH MMWG 2021L

FILE cOut_fslogi\ 230_p_HOBBSPVE1E3 TO1_211.5_3PR_SyCol out 1.5

F.1

2 g g 44. a4

51)

1

2016 MING FINAL W/TH 2015 SERIES MMWG FINAL MDWG 2021L 141.11,1 rtmn 2021L

FILE Wut_41.3\

414

"OO.. 31" NM MI F11,11.14,..4 G, 1,,,222 "l'53

'6' ca" 1.... A 'ice C

003144 000, ;10 IP) .715., "5417.-0 X II 141L._

0 0

C104114` 7410 . 11411. Orr 41114CLER-51144-541.414I0 0301

0 0 4 • 500,0

I I

1

I

...

t 1 1 , : 1

_

: 1

_

1 _ 1 _

_

)

-------------- ___:._ —

,........--_,e.r.V." 1

1 1 1 1 1 1

a r,

-111,L44 11 171121 ;14111!1020',X 1.1. 44 ."

". r r ,

.5l0. 4 MG, 011.105110042 120 000 11

....

0 50000

MM. 17 4 1/414GL-TOLT 1 124 000 11 4-- — -4 -0 5000

-100 0

11. 200 0

.-

—

—

—

_

I I

i

I

1 ,

• t 1

t'''

t

...4 t,

I

i

!

4

5

1

# i I 4

t i

,. .

. 1 1,

Ir

t

i

I

/ ....

_

--

tJ)

° 230_5P5

0,HOFBSPL3ISMOl

n231.5_3141.„SyColot

r: •

" C"2 100

4-4 4-1 Prr

F,

,',

14 ,

N

201,5 MDWO FINAL WITH 2015 SERIES MNRIG FINAL MDWG 2021L WITH WFWG 2021L 11,44.104


2019 TX Rate Case

RR 4 - Page 516 of 693 02325

2016 MDWG FINAL 14I15 2015 SERIES MIWG FINAL MDWG 2021L WITH MIMG 2021L

FILE \ Out_fillts3?1_345-230_,_11088,57LT1ta_31.3,21L5_3411.out

- 4.42 4241 •

.M1.24 15

C 5000f CM, 111

0 0 1111040 30

0 50000

10N4 15:010, 02255. 14 42

m04,4. -1.1,1o11, .13 POO 3.

LACCL -10.85 1417.3 111 000 1]

131.1.1.-001400 2 112 000 11

250 0

-0 5 000

I I I I I I I I I

1 ,

•um 2016 11:1740 =AL WITH 2015 SERIES 54.940 FINAL MOHO 20211. win *NIG 20211

FILE \Out_fileA 5-230_SPS_EFEISPL1153,311_21L5_3PH out •

.2. 1,55 0 2-, I.1721-2 '.PAIT .

11121.4 .14 5024 ,0 Pa 5

. ,

3 sto.,

05100,0 1 01 e L51,111. 17.4,

I, • .1 , 34 51

c v.

CHPILM 2 05 e MPG IIITC12128552 1451

1 0500

11—• 0 80000

-.2.-- .'.--'--" ;

.

—

—2

..

.,.......,:...222 ,--rn

10 .................* ........„.

.—

_

.........„,....* ...... 0 „7.s.........

.........„7,.....

...

,..C.....M 7 ----=,....., 2. 2,...2-..............- __.....

-,c----- e .._.-.

,6„...

-to- .m0

.. r - -

r"-"""

—, Ale-------

'- _

...........____--1.

.... 0.-.......................-- ,

r ---1--7 1 1

1

2015 MING FIEXL WITH 2 015 SERIES 541401 FINAL

IhAle• 551.10 20 21L WITH HMG 2022.1.

FILE \ Out_53.1.es P31_345- 230JPS_HOBBSPLS.163_413.1._21L5_3311 out

0.1)

0 FILE \O•at_f3.3.00\ P31_3,45-230_,P5_310,231?1,11‘3 .73.1_217.E_3P11 out.

L22016 MING FINAL W/114 2015 SERIES 51.1141 FINAL MING 20211 WITH 01101141 2021L

4t, =-4) a,

"00II.0 d F.4. 0 .....T•tk, • • , ,c -:

'1150 11 0101g. 02000040.. tr. 2.2.2 40 - -

.. 0

....

0

31141.0 4, 00401..021511105110112 110 104 1]

0H111.0 10, 1M405 -TOL r 1 124 OW 11

0 50000

.—.

-0 5000

I I 1 1 1 1

1

1 1 a g

-.

-

• ..... v _

_

-24•47- 7- 1-4.-- _1 . ...

-Mr-

_

., ....,:s, -Z. -,t7.1

—

....., 50 2 ......,..

—

.• ...Ow. 4, ...... .47,, ......

. . . . . . . . . . . . . '

7., ::: , c, , . • 4

1 ,,

, m........f .' "......'"5... d ...... ........ -

3:-5•

...-

-...ar .-••••••7

—

• :. ... .. "...:.

-2-'

—

.,,,-,-'•••-••...-

I

--,.

-•••

1 I

I I I I 1 I .I. I

pff —

10^ 011. PI 551'511.,.2D 0003n. , 413‘

100 e 0000 IP, Tult 11115.0,

•

1051„,_

0141150 594 5414 110 MR /TLER -ST110-10100512 1101

110( .-ZZIL•

11055.0

1111111111 P. °

—

g

• - ••••-••••,— !

t

—

l 1 1


2019 TX Rate Case

RR 4 - Page 517 of 693 02326

, ^

‘Out_fa.1•AD31_?.45-230_SPS)10131171.11.6.3_J11_211.5 3PH_SyCol out 04 ,

2 E

• : 504.,

1 0e0c

1 0500

.10,• .0 Mtn 1009 l 345'

04424 207 e 0u70 77200 2.52r 3451

C1014 005, IVIAG IIITC11.2,2 3451

n 2016 MDWG FINAL WIT'H 2015 SERIES HMG FINAL MDWG 2021L WITH MING 20211.

FILE- \Out_faes \11y4-230,SP,5410BBSYL:11&3 J11_2)15_3141 SyCol

. • 0.1, L MIME 9- 1 .t..• 1. r

, tk:11.1.4,10111.•• . .13 400

722721.• 21, 1-3.3C1,-21.300 41.77 .19 000 11 a 0 -4 -250 0

211414 37, 9.20L-3,20*C 0122004 11 0 50000 0 5000

1111

201G WING FINAL WITH 2015 SERIES MMHG FINAL MDWG 20211. WITH *SIG 20211

:DU 9135 0,.TIT

0,

2016 MDWG FINAL WITH 2015 SERIES MANG FINAL WDWG 20210 WITH MANG 2021L

FILE - \Out_fa.1•• \531,,?4,5-230_91431410116SPLTIL3 _.7117

21LS_GEFI_SyCol. out

2016 WING FINAL WI Di 2015 SERIES MENG FINAL

ti.

MDWG 20211 'Inn! MING 20211. ,-, CA

FILE Out_giles\ F?1_?45.-.230_SPS_HORRSPLUS,3_,711_1L5_3PH_SyCol out " ' • ,„„ .... .-1

`Ma 14.• IPÓ ]3r0-m02ÓI) D41••=1 '4'41

61141,42 2012, WI 101,71101 111T-0 r LI 7443

CIATL, 291, DM I 71 I.UtilZ-STLN-1044117 2003

1

1

L

1

„,_•—_-••

•

•

FILE

rill

•

- )

—

— o•••••••••••••••••.•••••

E,r, 4'77

110921,:121.pl7Ior,14: '30 04,0

031412,-0122Z20313M2 120 000 13

-220 1

VOGL-TM, 1 124 000 11 -0 5000

200 0

'1

•

7202.0 31 0

0 50000

-100 0

•31141,0 4r

CHNLY 17

Attachment BC-RR-4 Page 21 of 30

2019 TX Rate Case

RR 4 - Page 518 of 693 02327

201G MDWG FINAL WITR 2015 SERIES MMKG FINAL MDWG 2021L WITH MMWG 2021L

=LT smmere

FOIE C \Projects\ \Otatjl1ee\712_145,SPS410811SPL7143_,,02_21I5_3711 out . ,

:VW 1' R.I. -1,400 D.- . 114 . O. 1

t 1

M....... :, 0.4.01-1.11000.D . .0 WOO S.

t btu. com., 21, 10I01.-000020 P1203 _Or 000 11 ' - - - — * -0 1„0

0 o cAnTLit 37, 13000L-.7110E0 0 120.000 10

• —• — -41 - no 0

0 50000

4---4, 0 0000

r—

—

•

a

_

2

__

. .

s

1

1

" 2 4f•

.4.4 10,-A OM t .040

e ,

1 orti.,

to 4 t 0

011144 .ic7, mt., rix, um 3450

1 OGO0

• -- — 4 0 soott

10141,11 205 nanto ortd11.10 2451

1 1500

4-4 0 000.

IS,

f7-- 4.

/

1

—

—

.;

...1

— %,

ot

(

(

—

— _ 1

5

)

4 '')

1

--' 1 '...

;

.--

O

, (

il

—

1. tfi

.1

;

—

— S I

1 )

l; ft

, .C....'

, .11

...

,.:-... -.... ..::::.

11

41/4.4

P 00 .' H

FILE C \Projects\ \Out_files\!12_3,45 SPS_MOBBSOLTIta_J02_21LSJP11 out GI CO

.........7.., . 1—.

0 Z

,?1 g Cer I •—,Tt0

-4 ';'45 2 ...- 01 attUL 1121»m0.1701r .20 011 1: 012 o- • _.0 .

-1o11$ 4, 0,1=0.-G114110210142 12,1 000 11 0 50000

—

coma 17. Docb-TOLE l ID 000 0/

4— -4 -0 5000

--0 5000

•„.„

r "

„.•

_ — - ,. -------- ' 1 •••:-....

... — —

I I

2 201e MENG FINAL KM 2015 SERIES MMWG FINAL mprin 2021L WITH MMWG 2021L

F4LE, C \Projects\ \Out files\P32 34S_SPS,OBBSOLTt.Sa_502_211.5_3PII out

• 1 .e. I- — - -4 :Mao IV OM (PI otam, MOM" 1451

150 et 4- . cowl 110, :Mt (01 T11CO Dar-0 10 n 1411

--, 1

o 0 •-- — -4 mono 214, Del ,10, wErrule-striel-Dootec /DO

-.0 t

0 0

250 A

r' Ji

4' #

1 461

v.)

r' ,f,r 1 { t

/ , 1 7 I 1

isl

t.

/ Af

1 r1 1/4

C., r • ..„....,..

7, :.: .„,5 ,....,..0-

1:

--

—

_

1

-

1 - ,

0

----'---...----

- 1 i 111 1 1

LI201G MDWG FINAL WITV 2015 SERIES MMWG FINAL MDWG 2021L WITE MMWG 202101

FTLE C Projects Ou!., N,V32,3415_31:.5_11011171SPLTIO_JOR_3115_3PH t

g M

2

MImin 201G !CMG FINAL KIM 2015 SERIES HMG FINAL MDWG 2021L WITH MMWG 2021L

•,,


2019 TX Rate Case

RR 4 - Page 519 of 693 02328

FILE NOut_files‘173?_245_SPS,T113:5PFIS.3_0.2_211.5_3PH_SyCol out

im 2016 MDWG FINAL WITH 2015 SERIES HMG FINAL MING 2021L WITH VINNG 20211

PILE .102ut_fx2oW32 345_SPS,NOWISPLT10,702_22.L.5_3PR_SyCal.out -- — —I ... . , ..-

:11470* fl004. E3tC

24%11 2.9 0.1421.-010'13315 . .13 CO0 4,

C 50006

1J43

03041,4 21, 0.13101,115,1431 01,3 114 000 11

0,0

-250 0

0001.11 37, L0r,e1.-300E1 2 122 000 11

-4 5000

11

•

2016 MEWG FINAL WITH 2015 SERIES AMMO FINAL MDWG 2021L WITH MMHG 20211

FILE lOut_f12eux\P321

345_SPSJITNISPf...T1 go 2 _21L5_3Pii syG*1. out

IX. 2 — 11.11343 3.1154* "1

"R`L...,-, IN.TI MI ..

— --*

1 sco...

113104,41 IC, 145710, rut, Is,. 0410

• 0 0.

CM,. 205 i tv1(11G MTGE.* 3451

1 1500

• 0 90000

I I

I I l

i

I

1

1

1

.)

.}

--

I

I

--. _

......

.......__

I F 4 ,

i

1"

8i 0

....

—

_

_

- -. I I I

2016 MDWG FINAL WITH 2015 SERIES MMHG FINAL MDWG 2021L WITH MMHG 20211

00

PILE .\Out_fileo\P32 345_SP*,140BBSPIMs3 002_21L5_3911 SyCol out H

110 002

g o

&/ 2016 MDWG FINAL WITH 2015 SERIES MMKG FINAL MDWG 20211 WITH HANG 20211

,214. 0,-, Mik 17* L'11,31.32* avows 4471

011141.9 3000, [144 19/ 47130 Imr-to r 31 0451 -4

CMIII 231, DM 1P1 14!C31.4.4111.3C-DISCARC 2301

0 0

I

I I I I

; t

t II I , I 1 / ...

I 1,

1 f —

1 1

1 1

I f - , t i, _

1 t

1 i — 1 I (

5 ) 1

I

— I I i 111 I ,

,LL, II st*E, 134:144721; 1204 461 —

4*114 4, 10310,611/13311.13012 12, oon II

..

0 50000

4014.4 171 Fuoi—moldr 0 124 onn 11

.-- — •-• -e 5000

-120

, o

.—

.—

—

..

,—

—

...... _

I

--r

I

...! ...- - - -

I

..........- ......

I 1

I

14

i

I ......,

I

I

,

I t

5 1 I

'CU

0 50000

2

1


2019 TX Rate Case

RR 4 - Page 520 of 693 02329

2016 MDWG FINAL WITH 2015 SERIES MMKG FINAL MDWG 2021L WITH MMKG 2021L

=r11"

FILE C \Pr.:Q.:Iota\ \Out_files \ P32 345 SPS_HOBESPLTI&3,717_21L5_5PH out ...

351.4 ,,,,

01,04.7,1Wat 01:-1 .14 .4,

149901-01,0015 .0 .14 444

•

0,

,

c 50o.

aViLlt 21, 1.01491.1902940 PL1-3 .14 009 I.

01 • -4 1...

C1ONLP 30, COOL-J(7MS 2 122,000 11

0 50000

0,5000

I—

L

I- _

1 1

1 i i

—

-.

—

1

.... 1 ,

_ , 1 t .

iilimo I01G 327.

21S

,F.n.Li WIllj 3g1SEIIIES MING FINAL

F37.,E C \Projects\ . \Cout_f.2.3.0•\032

:345_SrS_E02,03PLT143_517,_21L5_3141 out

:214 r . II t4 LTA.T ..r o,e1

,4 0...T.: gel ,

01041.8 .i C, e Mr., TWO Dr' 145)

MCP 205. 0057.4 NITC11141,111 3451

1 0500

0 400.

tl

I tN, I

f

— 10,4

I • / t,

NI

I,

k

i{ ,

so ) „ Is ..,,,,

_ +. g t ' / 1

9-

1 N,

, ..)....,•

...-• AN. '',..

,— ...".".

..,.... .- •••-•

•••.-

l

1 i

', f : i

o' 1

' .1

x

i

• k

-: / ' 41

, 1

l f

.

_

_

—

—

' ^

, • ..••, ..•

1 I I i I I I ,

LIP

2016 MDWG FINAL WITH 2015 SERIES MMWG FINAL MDWG 2021L WITH MMWG 2021L

PILE C \ Prolects\ \Ouyi1.4\E.3

.0•;1 , Prr" ' ,1 4.9 ...'

.7,100L 01 14141,. 014994.750, 129. GK..,"

.. o

5

1114Lr 4 541429-01191101101942 120 000 17

049954 10, MEL-TOLL 0 124 002 11

0 500o0

0-0 o 5Doo

I I I r ..tl I I I 9

6/

-.

...

1

—

1

J 1 <

4 I ,

__

i L2

__

i k

1 .4

—

1 l'• ..,„

1 J

1 Oe

__

1 %

--

1 24

E —

, , 1

2

1 I

I i

—

—

_

— .... -

1

...

_

—1 ...

_

T

1

I I I i i

I 1 I

U 2016 MDWG FINAL WITH 2015 SERIES 14911 FINAL MIWG 2021L WITH 544WG 2021L

FTLE. c \pregeetA !Out PS WOBBEPLI:143._J17_21L5_3P1 ou

',Zs - ; -.4, i'FF F'4

"MN 10', Mk on 1'100111.18r Or1000'I 5 451

159 a" .

C111414 000, DM 1 DI 111020 01.0-0 r 51 0401

530 00 • — — -• •5. 0

014014 044. 000*100 il01lr1119-451,19-9450940 0001

0 0 • —• - 25 0 .0

- 1 1 1 ' A 8

i ' '.;

i l' i —

1 s

i

f

1 ., —

i 5',

1 "..;

J ,),/ i , , -

8

. Q

I ,

1

4 ..?"' ... ...... _

8

..-'? —

_l__ l II li i 1

i_SPE _liDELSPLII&3_,I17_211.5_3141 out


2019 TX Rate Case

RR 4 - Page 521 of 693 02330

.11114 1. MCI. MOP, AT- `.1 a, — 4—

ilmi

2016 MDWG FINAL WITH 2015 SERIES 141413 FINAL MDWG 20211 141711 IOW 20211.

FILE , \Cout_falez \ P32_345,

511.„140585PLT15 17_21L6_31.11 Sy= out „

L. 112.1. 441110

C 5:01.

02511.1 21, 12.101. ARMS PI, 211 000 11

4' • -.. 1. .0 2

02111.11 31, 2/201.-,01100 2 122 600 11

0 50000

P . -0 5000

I

.-...

—

1--

—

- •

I

II-1-- —22. --

I

I

..--

I

I

...—

I 1

I

I

I

I

I

I

I

I

—

.—,

.—.

—

..

••1

--

.1

1

2016 MCWG FINAL WITH 2015 SERIES 1411143 FINAL M1140 20211 WITH RING 20211

44444.0414

FILE \Out_fo1esV32 345 SPS IMBSPLT1s3 317 211,5 3PN SyC01.out

;test:" rim I .71Wr - ̀'.

Irl.. c-, 0s-,2 uot ,

1 ,

0 51,1

.11C1 214 . [WIT, 4131.2 INT 3151

I. • 0 0

OKRA' 105 . INLTG HITC111.4110 3151

4I • 0 .40000 1 300

1

0

I

I - I

- 1 I

1

- 1 1

_ i i ___ _ ...." _ --- ---

I I I I

, ,

1 I

i 1 I 1 1 . 1 1 1

) • 4, •

I I

.....

_

-

_

-

— ,m..

I 1 I I

I I I

2016 MDWG FINAL WITH 2011 SERIES MMKG FINAL MING 20211 WITH 14453 20211

\Out_filea\53?_345,3P9_13453139PLT153_J17..21L5_3PH_Šyall out -

--, ,r 4 Nor 1 1,47tX

-

12;10 11 DIGO tOE1=114; 114 44 ,

.. • WI 1

31111.4 1 I [331a16.03121512111012 1 21 on 11

o 50000

4— — - 4 - a s000

[HMO 11, 51.1.GL-TOLT 1 121 000 11

-130 t

1, • ,4t D

I I I 1 I

,

—

—

—

_

I .1. I 1

_

_

1

1 ,

_

r ,

I

) ,

s 1

_

_

s

1

...;

' '--.' I ''''.-`• —

...,. , ,„ I — .... --..

—

..•'• T 4., —

— ...- • 7- 1.. '.

1

0

1M2016 MEWG FINAL WITH 2015 SERIES teoic FINAL MING 20211 WITH 1f1141 20211

FILE 0000_fi1e!\!32_345_SPS_00E535PL11.53_317_331,4.)141_5y001 out

1,47,4 Ort '

TIT, LU, i01 I00Í !II TM:6,V 711511217

031111.4 102 :144 I 1,, T1132 010T- X 11 3153

e000r4 7111 111) 111112MIT-PTL21.001182 2301 500 00

0 0

I I

_a

;

1111 I h 1,1

250.0

1

MUM Ulm

FILE


2019 TX Rate Case

RR 4 - Page 522 of 693 02331

R2016 MDWG FINAL WITH 2015 SERIES MOM FINAL MDWG 2021L WITH 141445 2021L

FILE C \ Projects\ \Out,f1esW2,315_SPS_4DEIB.SPLT1s3_J19_2115_3P11 out

[4.04... rJen Pa ..... 1 I. C.

t IA i t et

.,,, Ift.NA -WAX. . -13 PW2 It

C soauc

400014 211 01000I.-01114. FL, .14 000 11 . a

(141014 37i 00I0L-JC0E5 2 122 .000 11

0 50000

- .- • -a 5 000

-.

1-

L _____

I

1 ........._

I

1 .....__

I

....._._ 1

I I

a

0.

1 1

I I

i I

-

-

--

_

_

....

-

.... -, i

Emin 2016 MING PCNAL WITH 2015 SERIES MING FINAL MING 2021L WITH Men 20211

PILE C \ Projects\ . \Out._f.

a.les \P2, 345...SFS_Iš BBSPL11.&3_J113_21L5_3PH out

^

1..15 • 1, Mt.. 0 2 411 . V.

'IMO 0 Mt:, AT._ r 20:

1 v40.,

asrst ay. ivra.•, TWO 111,1. 2451 0

1 Oalic

,. 0100

Clint 205 t I(VIC IiITCWILAND 3451 --, . 3000 0

/ I Ci I I

,_ \ i

* (

- I I A

i /

1

-, (

)

- .1 l

t t , 1

• k•

_.. __—

__ _.. --7-

;

I

-

-

-

_

_

-

..„.............-_:..

......z..

...

............................ mar.

-.......

1 I 1 I I

y

I 00=.4. 1 1.0005.0. a›.P1,241,Er.. 00..

11214 EMMA -01IS11,000142 117 000 11 0 50000

I I l

2016 MDWG FINAL WITH 2015 SERIES MMHG FINAL MDWG 20111 WITH MMWG 2021L

FILE C \ Projects \ j1les \?;32_?3

,15,SPS_HOBESPL.T1s3_,13.4_213.5- 3PH

•t904 t r. rl ••••••2

(1114.4 11. ITICI,TOM, 1 12 4 ono 1]

s,

t I

0

-0 5000

-0 5000

U2016 maic FINAL WI TH 2015 SERIES mmiqc FINAL MING 2021L WITH 534311 2021L

FILE- C \Projects\ \Out_fa.los \P32,.345,_SPS OOOBSPL7.1.3_J1 S._21L5_3P14 out

110a

1Pa'S -

:Me IV'. OM 101 .r.7.1,711,, t , trO.,rs tat

.

a- o- w mow 000, )sc (N TU. ten, r u 049

o o 41- — -.

rm.* 204 , 041,1 11,( 1414.1.04-51,1,1-1,*20C 2101 • 50 0 C

‘ I

i l 4,N

.

t 1 11/ i 4 t A

i

(7

:l

i ~..k

t

'17 • t

.•••.\

- l , I'

...;) W,'„,

• % ''

.--'..: t

- t ..."-..? ..:•.1,

..."3. .. -

.

.

e,'....;In..-,-...-


2019 TX Rate Case

RR 4 - Page 523 of 693 02332

Gut_plet \ .643?_300 _119BBSPIa1a3 J1E1_211.5_3PR Sy04o1

lim:

2 016 MDWG FINAL WITH 2015 SERIES MNMG FINAL MDWG 20211 WIIT MNVG 20211

FILE , \Out_fi1esP3.2

..345_S?S

.FIOBBSPLIIk3_0113_211.5_3141SyCo1 out

, .---

II

M‘• 29

1141. =Er PL.% '..., 909-

051201-01,1.120 .. ..3.4 POO L.

1 4

0 b00v2

1.93011.4 /Iv I0I0L-1.1.21 PLT3 .is 000 11

031.11.4 90. 1.41c1,,C•17.6 2 133 000 11

0 50000

-5 5000

—

_

L

h

I I i I I

1 1 1 1

--,

....

...

-.

—

—

.....

_

i 1

• mp 2016 MDWG FINAL WITH 2015 SERIES NMWG FINAL MING 20211 WIIH MMWG 20211

FILE ‘Out_fi2es\P3,21,

34.5_SPS_R9plil

.SPfal ,718_21L5_3PU_SfCb1 out

. .. . . •

ml.e,• - . otr . VaM -

: 50,

:Iigo. ..,-, ty-lt .4tcr 1 .4011

1 ,

4 50,

Cintl.• I11e 011111 TU., INC 3451

.... • t 0

1 aC0c

10141.0 205 e 011002 007C111.1140 3451

.— — -• 0 500t0

00

I.- • 0 90000

ir i i 1 1 i 1 1

i i /

.., ...... ..-

...

_

-

-

_

_

1 1 1

2016 MDWG FINAL WITT 2015 SERIES MMWG FINAL MDWG 20211 WITH MMWG 20211

,z...NO 10

r..4-1 ."9 "1- o"

IIML L2II0SE.1,3-

•

.12* Of, ".-

..DO .0

amuy 0 , 00.1=-6110[1.011042 120 000

.- • -_,3

12

0

CIFI21.4 17, 17.0.M.-00001. 1 124 000 11

-130 0

0

—

—

—

—

_

_

—

l

14

I

1

i

...

—

1

i

•

I

i

I. 1 ,

1

I

—

•

I

% i

i

%

i

i

4 i

f /

1.

kt /

2016 MDWG FINAL WITH 2015 SERIES MMWG FINAL MDWG 20211 WITT MMWO 20211

FILE Out_fi2es1032_345_SPS_HOBBSPIall3j113_211,5 2KI_Syeol out

NIX

• ..i., C

C14141.. 3nCe ;le 11,, .111 -11M-0 I ti 1451 0 0

• -- — -AI -500 C

0,44014 29r. NW 141 14Nre1.1M-0,TIAT-1010001C 2301 0 0

-

I

l

I I I I I I

>

.....

t

,...Z.....

.-.

)

/

—,

—

—

I

, :,...., ...,......05.0."

-... -7• 07 7. 1".."-

I I , I 1 1 1 l

Cri EI0

c..0

0,2

4/V••" --

=Wm,.

JIMMY FILE


2019 TX Rate Case

RR 4 - Page 524 of 693 02333

FILE C \ Project,/ \ \Out7f11es\1032_345_SPS_HOBBSPLTIC3_,230_211.5_31,14 out E, C \Projects\ \Out S_H00E1PLT11.3_520_21L5_3PH out

2016 MDWG FINAL WITH 2015 SERIES HMG FINAL MDWG 20211 WITH MMWG 2021L

FILE C \ Projects\ \Out_fslee \P32_345_SPS_BOBBSELT1S3_520_2115 3PH out H

H

:1411 ,,

:My 27••

34.1.4 Mee; a.- - :,.." ii„ .:

W4.1,401.10 • .13 100 1. r- —

t 7 4

C 53000

01141.1 211 00141,1107441 P1,0 111 000 11 a• - •• - • • •

CM. 37 r Gi2111.-J71410 2 122 000 11

0 50000

• —• -0 5000

.....

,...

I-...

.-.

.—

— --....

I

I

......—

I

-....

I

........

I

1

•

: I

,

•

I

I

I

II

I

I g ;

—,

g .., ,.

g ..-. :

g

—

i

2016 MDWG FINAL WITH 2015 SERIES MMWG FINAL MDWG 20211 WITH MMWG 2021/

FTLE C Ficuects \ . \Out_f21..0032_345_SPE_HOBESPLTIS3_320_2115_3PH out,

.0 MT: 4101

4 5

1 DJ 010E4 0 07 e LVI,Z, rUti, Ise 347)

1 OC CM* 005, 01,0 IIIT011J00 3451

4— — -4 0 50000

1 102

• —• o 40000

_

_

4

'".

....1:-.-

I

I I I t

I i

1 i

t 1 0 I

)

i I

t )

i ( I

1

1

ee , ' .....- ..%

...... _.—

, ---- — .,

1

1

1

\

_

_

.--

—

....

_

.7.":--:-0.. voraZ•amms• ammo ..16.,.......

I I I I

I I I

c.9 Z

4 a,

0 E

tlf

2016 MDWG FINXL WITH 2015 SERIES MMHG FINAL MDWG 20211 WITH MMWG 20212

,

I - , I. 0

.1.. • rar I r-n•vr "• 1

,naln. I 0 (Al.. n Arr,m,; 0 .44

4 ;

44.. ."

03/111 4 e 0111C1,1114101400.142 120 100 13 4-

4 -.4 1

r1Z1,11.1 17 r PICL-TOLIC 1 124 000 13

0 50000

I

1.....

_

__

—

—

—

—

__

__

I I

I

_.

I

1 t I I I

i I I i ' i i 1 I i I 1 1

1 i I I 1

1 I 1

1 1 s è

4 I t i ,... i 1

I i 1

I I 1 1

I

I

—,,,,—_—_.,,'„

I

I

, i I

l f

i i f

1

f 8

—

i

I

I

I

c

--

_

g

—

1

.

Li2016 MDWG FINAL WITH 2015 SERIES MMWG FINAL MDWG 20211 WITH MMWG 20211

•

Villa K. PA 4 01 .N.077'113120, liril>7.1^T 3470

. .. . -,0 r

011414 302 r ;144 (P), 'PIM 111T- 0 X 11 le]

0 0

4. -4 • 50 0 0

(10111 291, 1041 101 14/41.11,OTLII-DCHAP7 2301

0 0

• —• -25 0 G

I 1 1 I I. I

i I

: /

4

'5, k

1 / / __

t t 5 __

/0 /

', l __

4 ; i I I f k __

/ ,:•:: )

t

k c _

...^ _

•»004* ' ' s" -^." ..• ....., __

-...........,0 . 0‘ --''''. ' -0.,,,.,, ;,. .-.. ...*':

I 1 _L_, i I 11 1 i i

1


2019 TX Rate Case

RR 4 - Page 525 of 693 02334

1 Ott.

1 1500

2' • ra14 201,1T • 1' 2 101

4%3'1 4 L

511000 207, LVVII3 TUX, 1007. 9451 - 0 500CC

Cilladt 205 e NOG 1117050,1.1I) 3451 0 90000

1 1 1 1111

FILE \Out_21180\1,32_340_SPS7

1:0,21210,222.1.1.1.2_120_212,5_3141_SyCo ut

051 6 .•

0 0

0 0

1P.

moa,6 106 e :144 55170 X II 00. 3

elan* 294, NW (05 WIZCIACP-PTLH-DDIAAC 2301

1 m 2016 MDWG PDWAL WITH 2015 SERIES MMNG FINAL MDWG 20211 WITH MMNG 2021L

FILE ‘Out_fl1es\232_345 SPS_HOIIIISPI.T1 120 21L5_3PH_SyCol out ' • '

. , ,--,..--,.......

<

mt.

U2016 MDWG FINAL N1114 2015 SERIES tottic FINAL mDwG 20211 WITH mein 20211,

, Pf 007 We,. • 0:

*WA.,

1 1 1 ) 1

.11014, 2016 MDWG FINAL WITH 2015 SERIES MMKG FINAL MDWG 2021L WITH MMHG 20211

' •

50004

0 0

0 50000

.1 71 OWL 1514PL 0fl5 303,

1111 t•r•

1E10 21, 101CL-1.1031. IV, .14 000 13

311.114 2 132 000 11

UML= amen. PILE A0u0_folm\P32_345_20. 27H9313SPL112.3 120_211.5_3101_SyCca out

•

6

§ E.1

•

1 1 1 I ;L 1 1 1 I t

2016 MDWG FINAL WITH 2015 SERIES MMHG FINAL 511640 20211 WITH mmWG 2021L

PILE .\Out_Xi1e.\222 345722,2_001125PL1103 120_21L5_3101 SyCol out

-1-D0 , Orl

..nrIg! 11 . 02050 :110.1,147'..0. OW

511111.0 4 e [10.1.-(110.11060012 12, 000 11

CNICI4 17 e 011fl1.-.7•31..T 1 124 000 13


2019 TX Rate Case

RR 4 - Page 526 of 693 02335

1111

rIOPM 2016 MDWG FINAL WITH 2015 SERIES MNWG FINAL MDWG 2021L WITH MMWG 2021L

2016 MING FINAL WITH 2015 SERIES MMWG FINAL MING 20211 WIIE MMHG 2021L

nwonww

FILE AOut_fslea\f327

345-230_S!S_ROBBS,PLT3_4701_21J,4_3141_,SyCol out

El. 2016 MDWG FINAL WIIII 2015 SERIES MFG FINAL MDWG 2021L WITH ARNO 2021L

FILE \Out_fl2ea\512_45-210_59SitOB5S5L73_701_2115_14kp3Col t a

2E

4 ca, En

P

1 1 1 1

• m 2016 MDWG FINAL WITH 2015 SERIES MMWG FINAL MDWG 20211 WIIR MSG 2021L

FILE. AOut_fIles\P327

3:15:

230, SRS_MIESPZT3301_21LS,1011_SyCol out .

• , •I`t.

iPto. -v. a V.1.1 PM ,

. i

I' 5042 mad 2c, iv1,70 TUN Ilvr N0)

0 0

0101114 205 t !WAG 011,91.21. 3451

1 0500

0 0 $0000

I-.....i.-e

.....

...,

--,-,...

....- .

.-..

.....

..........

.. --

....-...-.

.......

.........

. ......

...

, I 1

-

I -

I ;

-

A l

i i

l I

l i

i I

§

•

0

0 50000

- J 240

-250 0

5000

FILE \Out_filos\232_345-230_5f?_5086321,73_,701_21L5_3PHJyCol out

.

- , ,

MAO 11 DX,. 02100.0=1010 ..12.1 04. 7. - 0 0

a011.4 4 r

4_ . J MI0I.-CUNI14CSI2142 120 000 11

14101/1 17, 121C1.-TOLX 1 124 000 11 -10o o

• —• -200 0

....•

,-..

—

—

—

I

I

I

l

I

--------- --------

/

/

I

i

1

1 i .

t / 4%

se 1 , :,

‘I

..

—

:I

I

-216. sC• 1511 iin GIT1'112.4., irMary '441

'2 005

.- .

00711.4 105, 'IV 0 9‘ MCC INT-0 X U 147]

O..* .. 1740 111 01115512P-OTIM-IMIT0OO 2203

0 0

-250 0

•

1 .

• i

1

1

i

I

t J i

I;

i

4.

.. ........

.....

.-:=4,1e1.0....-.-' .. ..7 ....7.1.

,

1

7

8

2

!

1

8 8

1

1, 211e .7 1.2. •

•

••• •••1

ZA, 41. 29 WWI. -101,0 21$ .71 41,0

.71.4 210 02120-11,14. 1,1, 014 002 10 4-- — -0

CIONLV 37. 100cI,-.72IO2s 2 122,006 11


2019 TX Rate Case

RR 4 - Page 527 of 693 02336

DOCKET NO.

APPLICATION OF SOUTHWESTERN § PUBLIC UTILITY COMMISSION PUBLIC SERVICE COMPANY FOR § AUTHORITY TO CHANGE RATES § OF TEXAS

DIRECT TESTIMONY of

DAVID A. LOW

on behalf of

SOUTHWESTERN PUBLIC SERVICE COMPANY

(Filename: LowRRDirect.doc)

Table of Contents

GLOSSARY OF ACRONYMS AND DEFINED TERMS 4

LIST OF ATTACHMENTS 6

I. WITNESS IDENTIFICATION AND QUALIFICATIONS 8

II. ASSIGNMENT AND SUMMARY OF TESTIMONY AND RECOMMENDATIONS 11

III. DESCRIPTION OF RATE FILING PACKAGE SCHEDULES 19

IV. GENERATING FACILITIES 22

V. ENERGY SUPPLY O&M EXPENDITURES 24

VI. HALE WIND PROJECT O&M EXPENDITURES 29

VII. AFFILIATE CLASSES SPONSORED 36

VIII. AFFILIATE EXPENSES FOR THE ES PROJECTS CLASS OF SERVICES 37

A. SUMMARY OF AFFILIATE EXPENSES FOR THE ES PROJECTS CLASS OF SERVICES 37

B. THE ES PROJECTS CLASS OF SERVICES ARE NECESSARY SERVICES 45

C. THE ES PROJECTS CLASS OF SERVICES ARE PROVIDED AT A REASONABLE COST 48

1. ADDITIONAL EVIDENCE 49

2. BUDGET PLANNING 49

3. COST TRENDS 51

4. STAFFING TRENDS 52

5. COST CONTROL AND PROCESS IMPROVEMENT INITIATIVES 52

D. THE COSTS FOR THE ES PROJECTS CLASS OF SERVICES ARE PRICED IN A FAIR MANNER 53

Low Direct — Revenue Requirement Page I

RR 4 - Page 528 of 693 02337

IX. AFFILIATE EXPENSES FOR THE ES ENVIRONMENTAL CLASS OF

SERVICES 57

A. SUMMARY OF AFFILIATE EXPENSES FOR THE ES ENVIRONMENTAL

CLASS OF SERVICES 57

B. THE ES ENVIRONMENTAL CLASS OF SERVICES ARE NECESSARY

SERVICES 60

C. THE ES ENVIRONMENTAL CLASS OF SERVICES ARE PROVIDED AT A

REASONABLE COST 62



3. COST TRENDS 64



D. THE COSTS FOR THE ES ENVIRONMENTAL CLASS OF SERVICES ARE

PRICED IN A FAIR MANNER 67

X. AFFILIATE EXPENSES FOR THE ES PERFORMANCE

OPTIMIZATION CLASS OF SERVICES 71

A. SUMMARY OF AFFILIATE EXPENSES FOR THE ES PERFORMANCE

OPTIMIZATION CLASS OF SERVICES 71

B. THE ES PERFORMANCE OPTIMIZATION CLASS OF SERVICES ARE

NECESSARY SERVICES 75

C. THE ES PERFORMANCE OPTIMIZATION CLASS OF SERVICES ARE

PROVIDED AT A REASONABLE COST 77



3. COST TRENDS 79



D. THE COSTS FOR THE ES PERFORMANCE OPTIMIZATION CLASS ARE

PRICED IN A FAIR MANNER 81

XI. AFFILIATE EXPENSES FOR THE ES VP ENERGY SUPPLY CLASS

OF SERVICES 85

A. SUMMARY OF AFFILIATE EXPENSES FOR TIIE ES VP ENERGY

SUPPLY CLASS OF SERVICES 85

B. THE ES VP ENERGY SUPPLY CLASS OF SERVICES ARE NECESSARY

SERVICES 88

C. THE ES VP ENERGY SUPPLY CLASS OF SERVICES ARE PROVIDED AT

A REASONABLE COST 90



3. COST TRENDS 92

Low Direct — Revenue Requirement Page 2

RR 4 - Page 529 of 693 02338



D. THE COSTS FOR THE ES VP ENERGY SUPPLY CLASS OF SERVICES ARE PRICED IN A FAIR MANNER 94

XII. AFFILIATE EXPENSES FOR THE ES VP OPERATIONS CLASS OF SERVICES 98

A. SUMMARY OF AFFILIATE EXPENSES FOR THE ES VP OPERATIONS CLASS OF SERVICES 98

B. THE ES VP OPERATIONS CLASS OF SERVICES ARE NECESSARY SERVICES 101

C. THE ES VP OPERATIONS CLASS OF SERVICES ARE PROVIDED AT A REASONABLE COST 103



3. COST TRENDS 105



D. THE COSTS FOR THE ES VP OPERATIONS CLASS OF SERVICES ARE PRICED IN A FAIR MANNER 107

XIII. SPS POWER PLANT O&M PROGRAMS 112

A. SCHEDULED MAINTENANCE PRACTICES 1 12

B. PREDICTIVE MAINTENANCE PRACTICES 115

C. PERFORMANCE ASSURANCE PROGRAMS 120

D. TRAINING OF PLANT OPERATORS AND MAINTENANCE PERSONNEL 130

XIV. RESULTS OF SPS'S O&M PRACTICES 133

XV. OUTAGES 140

AFFIDAVIT 143


RR 4 - Page 530 of 693 02339

GLOSSARY OF ACRONYMS AND DEFINED TERMS

Acronvm/Defined Term Meaning

Btu British thermal unit

EAF Equivalent Availability Factor

ES Energy Supply business area including both native and affiliate activities

FERC Federal Energy Regulatory Commission

FOR Forced Outage Rates

IM Integrated Marketplace

kWh kilowatt hour

LP Low Pressure

M&D Monitoring and Diagnostic

MW megawatt

MWh megawatt hour

NERC

NERC/GADS

North American Electric Reliability Corporation

North American Electric Reliability Corporation/Generating Availability Data System

NMPRC New Mexico Public Regulation Commission

O&M Operation and maintenance

OEM Original Equipment Manufacturer


RR 4 - Page 531 of 693 02340

Acronvm/Defined Term Meaning

Operating Companies Northern States Power Company, a Minnesota corporation; Northern States Power Company, a Wisconsin corporation; Public Service Company of Colorado, a Colorado corporation; and SPS.

Operating Company One of the Operating Companies

PTT Productivity through Technology

RFP Rate Filing Package

SMWA Service Maintenance and Warranty Agreement

SPP Southwest Power Pool, Inc.

SPS Southwestern Public Service Company, a New Mexico corporation

Test Year April 1, 2018 through March 31, 2019

Total Company or total Total SPS (before any jurisdictional company allocation)

Update Period April 1, 2019 through June 30, 2019

Updated Test Year July 1, 2018 through June 30, 2019

Vestas Vestas-American Wind Technology, Inc.

VP Vice President

Wind Lease Agreement Lease and easement agreement between SPS and a landowner related to the Hale Wind Project

Xcel Energy Xcel Energy Inc.

XES Xcel Energy Services Inc.


RR 4 - Page 532 of 693 02341

LIST OF ATTACHMENTS

Attachment Description

DAL-RR-1 Energy Supply Organization Chart (Non-native format)

DAL-RR-2(V)(HS) Service, Maintenance, and Warranty Agreement between Southwestern Public Service Company and Vestas-American Wind Technology, Inc. dated as of June 15, 2018 (Non-native format)

DAL-RR-3(HS) Wind and Easement Lease Agreement (Non-native format)

DAL-RR-4 Tolk Station Annual Equivalent Availability Factors (Filename: DAL-RR-4.xls)

DAL-RR-5

DAL-RR-6

Harrington Station Annual Equivalent Availability Factors (Filename: DAL-RR-5.xls)

Gas Units (200-299 MW) Annual Equivalent Availability Factors (Filename: DAL-RR-6.xls)

DAL-RR-7 Tolk Station Annual Forced Outage Rates (Filename: DAL-RR-7.xls)

DAL-RR-8 Harrington Station Annual Forced Outage Rates (Filename: DAL-RR-8.xls)

DAL-RR-9

DAL-RR-10

Gas Units (200-299 MW) Forced Outage Rates (Filename: DAL-RR-9.xls)

SPS Native Operation and Maintenance Expenses (Filename: DAL-RR-10.xlsx)


RR 4 - Page 533 of 693 02342

Attachment Description

DAL-RR-A Summary of XES Expenses to SPS by (Updated Test Year) Affiliate Class and Billing Method

(Filename: DAL-RR-ABCD.xlsx)

DAL-RR-B(CD) XES Expenses by Affiliate Class, Activity, (Updated Test Year) Billing Method and FERC Account


DAL-RR-C Exclusions from XES Expenses to SPS by (Updated Test Year) Affiliate Class and FERC Account


DAL-RR-D Pro Forma Adjustments to XES Expenses (Updated Test Year) by Affiliate Class and FERC Account



RR 4 - Page 534 of 693 02343

DIRECT TESTIMONY OF

DAVID A. LOW

1

I. WITNESS IDENTIFICATION AND QUALIFICATIONS

2 Q. Please state your name and business address.

3 A. My name is David A. Low. My business address is 790 S. Buchanan Street,

4

Amarillo, Texas, 79101.

5 Q. On whose behalf are you testifying in this proceeding?

6 A. I am filing testimony on behalf of Southwestern Public Service Company, a New

7

Mexico corporation ("SPS") and wholly-owned electric utility subsidiary of Xcel

8

Energy Inc. ("Xcel Energy").

9 Q. By whom are you employed and in what position?

10 A. I am employed by SPS as General Manager, SPS Generation.

11 Q. Please briefly outline your responsibilities as General Manager, SPS

12

Generation.

13 A. I am responsible for providing management for the SPS Generation business area

14

within the Energy Supply organization, which provides leadership, strategic

15

direction, and management of the power generation group within the SPS area of

16

Xcel Energy.

17 Q. Please describe your educational background.

18 A. I received a Bachelor of Science in Mechanical Engineering Technology from

19

Texas Tech University in 1983. I also completed course work toward an MBA at

20

West Texas A&M University from 1998 to 2001.


RR 4 - Page 535 of 693 02344

1 Q. Please describe your professional experience.

2 A. I began my career with SPS in 1983 as a Plant Engineer at Tolk Station. I was

3 promoted to Supervisory Plant/Project Engineer at Tolk Station in 1987. In 1992,

4 I was promoted to Senior Project Engineer at Tolk Station. Then, in 1995, I

5 became the Maintenance Manager for SPS's Harrington Station. In 2003, I was

6 promoted to Plant Director for Public Service Company of Colorado's Pawnee

7 Station. In 2007, I was promoted to Plant Director of SPS's Tolk and Plant X

8 Complex. Finally, in 2011, I was promoted to my current position as General

9 Manager, SPS Generation.

10 Q. Have you attended or taken any special courses or seminars relating to

1 1 public utilities?

12 A. Yes. Over my career, I have taken various courses and seminars related

13 specifically to the public utility industry.

14 Q. Have you testified before any regulatory authorities?

15 A. Yes. I filed testimony at the Public Utility Commission of Texas in Docket

16 Nos. 40824, 42004, 43695, 45524 and 47527, SPS's last five base rate cases, on

17 Energy Supply affiliate expenses, SPS's generation by operating plant and unit,

18 and its power plant operation, maintenance, and cost control practices. I also

19 testified at the New Mexico Public Regulation Commission ("NMPRC") in Case

20 No. 12-00350-UT, on SPS's known and anticipated operation and maintenance

21 ("O&M") expenditures related to chemical and water usage for power plants. In

22 addition, I have filed testimony on SPS's behalf before the NMPRC in Case Nos.


RR 4 - Page 536 of 693 02345

1 14-00348-UT, 15-00296-UT, 16-00269-UT, and 17-00255-UT addressing SPS's

2 generation and its power plant operation, maintenance, and cost control practices.


RR 4 - Page 537 of 693 02346

1 II. ASSIGNMENT AND SUMMARY OF TESTIMONY AND 2 RECOMMENDATIONS

3 Q. What is your assignment in this proceeding?

4 A. I support the Updated Test Year (July 1, 2018 through June 30, 2019)1 O&M

5 expenses and the administrative and general expenses in the Energy Supply

6 ("ES") business area overall, which includes native costs and the following five

7 classes of affiliate services:

8 1. ES Projects;

9 2. ES Environmental;

10 3. ES Performance Optimization;

11 4. ES Vice President ("VP") Energy Supply; and

12 5. ES VP Operations.

13 I will also discuss SPS's generation by operating plant and unit, and its power

14 plant operation, maintenance, and cost control practices during the Updated Test

15 Year. In addition, I explain SPS's approach to supporting the O&M needs of the

16 Hale Wind Project, which began commercial operations in June 2019, and support

17 SPS's request for the known and measurable O&M expenses for that facility.

18 Finally, I sponsor or co-sponsor schedules in SPS's Rate Filing Package ("RFP")

19 and the portions of the Executive Summary that contain information from these

20 schedules.

1 The Test Year in this case is April 1, 2018 through March 31, 2019, and the Update Period is April I, 2019 through June 30, 2019. The Updated Test Year consists of the last nine months of the Test Year and the three months in the Update Period (i.e., July 1, 2018 — June 30, 2019). In addition to supporting the Updated Test Year costs, I have also reviewed the costs for the first three months of the Test Year for the native costs and affiliate classes I support and find those costs to be reasonable.


RR 4 - Page 538 of 693 02347

1 Q. Please summarize your testimony and recommendations.

2 A. SPS operates and maintains its generating facilities in an efficient and reliable

3 manner:

4 • SPS uses tools such as PLEXOS software to schedule maintenance or 5 overhauls on a component basis (instead of complete or major unit 6 overhauls) which helps stabilize maintenance costs from year to year and 7 ensures the efficient and reliable operation of SPS's units;

8 • SPS uses a proactive predictive maintenance program that helps minimize 9 costs, while maintaining unit reliability;

10 • SPS maintains a robust performance assurance program, which includes 11 ongoing monitoring of power plant performance, to improve unit 12 efficiency and find cost-effective ways to reduce fuel costs;

13 • SPS's coal units performed well during the Test Year, most operating 14 within 3% of their Adjusted Design Net Heat Rate; and

15 • During the Test Year, SPS conducted a Steam Path Analysis on Tolk 16 Unit 1, Jones Unit 2, and Harrington Unit 1 turbines, which resulted in 17 greater fuel savings and improvements in heat rates for those units;

18 • SPS requires and provides training of plant operators and maintenance 19 personnel to ensure the safe and reliable operation of its units;

20 • Although SPS continues operating in an efficient manner, the changes to 21 the Southwest Power Pool Inc.'s ("SPP") market has increased unit starts 22 and shortened unit service hours, which has increased O&M expense and 23 will likely do so in the future;

24 In comparison to other utilities, SPS's O&M programs for generation facilities are

25 highly effective:

26 • The overall Equivalent Availability Factor ("EAF") for SPS's coal and gas 27 units compare favorably with the national average for 2017, the most 28 recent North American Electric Reliability Corporation ("NERC") 29 publication of these metrics;

30 • The overall Forced Outage Rates ("FOR") of SPS's coal and gas units also 31 compare favorably to the national average in 2017; and


RR 4 - Page 539 of 693 02348

1 • Although SPS had several unplanned outages during the Test Year, SPS 2 took all reasonable steps to avoid unplanned outages and to quickly make 3 repairs and bring plants back on-line when needed.

4 Native O&M Expenses — The amounts included in Attachment DAL-RR-10

5 represent, at a total company level, reasonable and necessary Energy Supply

6 O&M costs incurred by SPS to provide safe and reliable electric service to its

7 Texas retail customers.

8 Hale Wind Project O&M Expenses - SPS's approach to O&M for the Hale Wind

9 Project leverages Xcel Energy's experience with other wind projects and

10 efficiently uses experienced contractors and internal personnel. In this case, SPS

11 is requesting a known and measurable adjustment to reflect its O&M expenses for

12 its Service, Maintenance, and Warranty Agreement ("SMWA") with Vestas-

13 American Wind Technology, Inc. ("Vestas"), and for the land lease expenses that

14 SPS will incur during the period rates are in effect. Those costs are reasonable

15 and known and measurable.

16 Affiliate O&M Expenses - The Updated Test Year costs that SPS seeks to recover

17 for the services of each of the five affiliate classes that I support are reasonable

18 and necessary because they support SPS's ability to provide electric service to its

19 Texas retail customers.

20 ES Projects

21 • The estimated Updated Test Year (July 1, 2018 through June 30, 2019) 22 costs for the services of the ES Projects affiliate class that SPS seeks to 23 recover are $690,333 (total company).2

2 "Total company" means the total amount for SPS, before any jurisdictional allocation.


RR 4 - Page 540 of 693 02349

1 • The costs are for services provided to SPS that include Texas and New 2 Mexico regional capital engineering, design and document services, and 3 construction and project services. These services are necessary to provide 4 the generation plant and systems that enable the provision of safe and 5 reliable electric service to SPS's customers.

6 • The costs are reasonable because they are shared with other affiliates, 7 include reasonable personnel costs, and are subjected to rigorous 8 budgeting and cost control processes.

9 • SPS does not provide these services for itself, and the services do not 10 duplicate services provided by others.

11 • Each charge from SPS's affiliates for these services is no higher than the 12 charge by those affiliates to any other entity for the same or similar 13 service.

14 ES Environmental

15 • The estimated Updated Test Year costs for the services of the ES 16 Environmental affiliate class that SPS seeks to recover are $1,678,242 17 (total company).

18 • The costs are related to services to help ensure plant facilities remain in 19 environmental compliance, including obtaining permits for new and 20 existing facilities and chemistry water resources . These services are 21 necessary to ensured continued, regulatory-compliant, operation of SPS's 22 generation plant facilities.




31 ES Performance Optimization

32 • The estimated Updated Test Year costs for the services of the ES 33 Performance Optimization affiliate class that SPS seeks to recover are 34 $8,044,339 (total company).


RR 4 - Page 541 of 693 02350

1 • The costs are for plant engineering and technical support, asset 2 management, overhaul management and maintenance support, 3 performance testing and analysis, and reliability maintenance services. 4 These services are necessary to ensure the safe and reliable operation of 5 SPS's generation fleet.




14 ES VP Energy Supply

15 • The estimated Updated Test Year costs for the services of the ES VP 16 Energy Supply affiliate class that SPS seeks to recover are $143,089 (total 17 company).

18 • The costs are for the oversight of VP Performance Optimization, VP 19 Projects, and VP Operations. The services provided by this oversight 20 function are necessary to ensure cost control, engineering and construction 21 execution, technical support, and operational excellence of SPS's 22 generation fleet.




31 ES VP Operations

32 • The estimated Updated Test Year costs for the services of the ES VP 33 Operations affiliate class that SPS seeks to recover are $462,122 (total 34 company).


RR 4 - Page 542 of 693 02351

1 • The costs are for oversight and management of the Operating Mode13 2 across the Xcel Energy fleet and regional generation organizations, and to 3 provide performance indicators and lead the Energy Supply safety 4 program. These services are necessary to provide leadership in ensuring 5 the safe and reliable operation of SPS's generation facilities.




14 Q. You mention that certain costs that you present in your testimony are

15 estimates. Please explain why this is the case and what items are estimates.

16 A. As explained by SPS witness William A. Grant, SPS will be using an Updated

17 Test Year in this case. SPS's initial filing presents actual expenses for the Test

18 Year (April 1, 2018 through March 31, 2019) and estimated information for the

19 Update Period (April 1, 2019 through June 30, 2019). Accordingly, the first nine

20 months of SPS's Updated Test Year (i.e., July 2018 through March 2019) consist

21 of actual cost information and the last three months (i.e., April through June 2019)

22 contain estimated cost information. For this reason, certain SPS witnesses refer to

23 the Updated Test Year in direct testimony as the "estimated Updated Test Year."

24 Regarding the ES Projects, ES Environmental, ES Performance

25 Optimization, ES VP Energy Supply, and ES VP Operations affiliate costs I

26 support, as explained by SPS witness Melissa L. Schmidt, actual figures for April

3 The "Operating Model" or "Generation Operating Model" provides for the alignment of resources and standardization of the key elements of organizational operation to identify best practices, reduce operating and maintenance cost, and promote excellence.


RR 4 - Page 543 of 693 02352

1 and May 2019 have been provided and June 2019 figures have been estimated

2 based on the forecasted budget. However, these expenses have not gone through

3 the full pro forma adjustment review process.

4 Regarding the native SPS costs for Energy Supply O&M that I support,

5 which are provided in my Attachment DAL-RR-10, as explained by SPS witness

6 Arthur P. Freitas, actual figures for April and May 2019 have been provided, and

7 June 2019 figures have been estimated based on the forecasted budget.

8 Q. Will your testimony be updated to replace the estimated costs that you

9 present and support with actual costs?

10 A. Yes. SPS will file an update 45 days after the application has been filed. The

11 update will provide actual costs to replace the estimates provided in the

12 application for the Update Period. As part of that process, my Attachments DAL-

13 RR-A through D will be updated to remove estimates of ES Projects, ES

14 Environmental, ES Performance Optimization, ES VP Energy Supply, and ES VP

15 Operations affiliate O&M expenses incurred by SPS during the Updated Test

16 Year and then replace those estimates with actual expenses, which will be used to

17 establish SPS's base rates in this case. Additionally, my Attachment DAL-RR-10

18 will be updated in SPS's 45-day update filing to replace estimates of SPS's native

19 costs relating to Energy Supply O&M with actuals.


RR 4 - Page 544 of 693 02353

1 Q. Were Attachments DAL-RR-1, DAL-RR-4 through DAL-RR-11, and DAL-

2 RR-A through DAL-RR-D prepared by you or under your direct supervision

3 and control?

4 A. Yes, as to Attachments DAL-RR-1, DAL-RR-4 through DAL-RR-9 and DAL-

5 RR-11. Attachment DAL-RR-10 was prepared by SPS witness Arthur P. Freitas

6 and his staff and is based on the cost of service study. Attachments DAL-RR-A

7 through DAL-RR-D were prepared by Ms. Schmidt and her staff. My staff and I

8 have reviewed these attachments, and I believe them to be accurate. Although the

9 information I have described also is present in Ms. Schmidt's attachments, I have

10 presented this information in the attachments to my testimony for the convenience

11 of those reviewing my testimony.

12 Q. Are Attachments DAL-RR-2 and DAL-RR-3 true and correct copies of the

13 documents you describe?

14 A. Yes.

15 Q. Were the portions of the RFP schedules you sponsor or co-sponsor prepared

16 by you or under your supervision and control?

17 A. Yes.

18 Q. Do you incorporate the portions of the RFP schedules and the Executive

19 Summary sponsored or co-sponsored by you into this testimony?

20 A. Yes.


RR 4 - Page 545 of 693 02354

1 III. DESCRIPTION OF RATE FILING PACKAGE SCHEDULES

2 Q. What RFP schedules do you sponsor?

3 A. I sponsor or co-sponsor the following RFP schedules:

4 Table DAL-RR-I

H Schedules 1, 1.2, 1.2a, 1.2a1, 1.2a2, 1.2b, 1.2c, 1.2d, 2, 3, 4, 6.2a, 6.2b, 6.2c, 6.3b, 7.1, 7.2, 7.3, 7.4, 7.5, 8, 9, 11.1, 11.2, 11.3, 12.2a, 12.2a1, 12.2b, 12.2b1, 12.2c, 12.2c1, 12.3a, 12.3b, and 12.3c

I Schedules 5.1, 5.2, and 5.3

5 Q. What information is contained in the H schedules?

6 A. The H schedules I sponsor or co-sponsor contain the following information:

7 • Schedule H-1 provides in summary form, the production plant 8 operations and maintenance expenses (excluding fuel) by month for 9 the Test Year and Updated Test Year, by the Federal Energy

10 Regulatory Commission ("FERC") account, by primary fuel type, for 11 all generating plants or units. Schedule H-1.2 provides total company 12 O&M expenses for fossil plants. I co-sponsor this schedule with Mr. 13 Freitas.

14 • Schedule H-1.2a provides a summary of O&M expenses for natural 15 gas plants. I co-sponsor this schedule with Mr. Freitas.

16 • Schedule H-1.2a1 provides O&M expense for natural gas plants 17 (steam generation). I co-sponsor this schedule with Mr. Freitas.

18 • Schedule H-1.2a2 provides O&M expense for natural gas plants 19 (combustion turbine). I co-sponsor this schedule with Mr. Freitas.

20 • Schedule H-1.2b provides a summary of O&M expense for coal plants. 21 I co-sponsor this schedule with Mr. Freitas.

22 • Schedule H-1.2c provides a summary of O&M expense for lignite 23 plants.

24 • Schedule H-1.2d provides a summary of O&M expense for other 25 plants. I co-sponsor this schedule with Mr. Freitas.


RR 4 - Page 546 of 693 02355

1 • Schedule H-2 provides production adjusted O&M expense for the Test 2 Year and Updated Test Year. I co-sponsor this schedule with Mr. 3 Freitas.

4 • Schedule H-3 provides the summary of actual production O&M 5 expenses incurred.

6 • Schedule H-4 provides a list of all projects, in excess of $100,000, to 7 be charged to production O&M expense in the most current budget or 8 projection.

9 • Schedule H-6.2a provides a list of fossil unit forced outages that 10 occurred during the Test Year.

11 • Schedule H-6.2b provides a list of scheduled outages of fossil units 12 that occurred during the Test Year.

13 • Schedule H-6.2c provides a list of each outage for fossil units 14 scheduled for the next five calendar years.

15 • Schedule H-6.3b provides the incremental cost information for the 16 Test Year for each fossil unit outage, excluding outage costs under 17 $500,000.

18 • Schedule H-7.1 provides a copy of the most recent total company 19 production staffing plan.

20 • Schedule H-7.2 provides a copy of the most recent plan used for 21 personnel staffing.

22 • Schedule H-7.3 provides a summary schedule of the number of 23 personnel assigned to each plant on a calendar year basis during the 24 preceding five calendar years.

25 • Schedule H-7.4 provides a listing of the average number of personnel 26 assigned to each unit for the Test Year, and projected for the rate year.

27 • Schedule H-7.5 provides the production O&M organization charts for 28 plants, systems operations, and corporate personnel with the associated 29 number of personnel.

30 • Schedule H-8 provides a summary of the system-wide production 31 operations programs.

32 • Schedule H-9 provides a summary of the system-wide production 33 maintenance programs.


RR 4 - Page 547 of 693 02356

1 • Schedule H-11.1 provides the percentage of O&M expenses 2 (excluding fuel) per total production plant expenses (excluding fuel) 3 annually for the Test Year and the previous five years by plant.

4 • Schedule H-11.2 provides the percentage of preventative (including 5 predictive) maintenance man-hours and corrective maintenance 6 man-hours versus the total maintenance man-hours.

7 • Schedule H-11.3 provides the O&M costs (excluding fuel) per 8 megawatt hour ("MWh") generated by each plant grouped by primary 9 fuel type on a monthly and annual basis for the Test Year, and the

10 previous five years.

11 • Schedules H-12.2a and H-12.2a1 provide MWh production by lignite 12 and coal units for the Test Year and the previous five years.

13 • Schedules H-12.2b and H-12.2b1 provide MWh production by unit for 14 natural gas and oil units for the Test Year and the previous five years.

15 • Schedules H-12.2c and H-12.2c1 provide MWh production for other 16 units during the Test Year and previous five years.

17 • Schedules H-12.3 a, H-12.3 b, and H-12.3 c provide generating unit 18 data, unit characteristics, and efficiency and control systems.

19 Q. What information is contained in the I schedules that you sponsor?

20 A. Schedules 1-5.1, 1-5.2, and 1-5.3 provide information regarding combustion

21 residual production, disposal, and disposal costs.

22 Q. Will any of the schedules that you sponsor be updated?

23 A. Yes. Schedules H-1, H-1.2, H-1.2a, H-1.2a1, H-1.2a2, H-1.2b, H-1.2d, and H-2

24 will be updated in the case update filing 45 days after the application is filed.


RR 4 - Page 548 of 693 02357

1 IV. GENERATING FACILITIES

2 Q. Please describe SPS's generating facilities.

3 A. SPS had the following generating facilities in service during the Test Year:

Steam Production — Gas/Oil • Jones Unit 1 • Jones Unit 2 • Plant X Unit 1 • Plant X Unit 2 • Plant X Unit 3 • Plant X Unit 4

Steam Production — Gas • Cunningham Unit 1 • Cunningham Unit 2 • Maddox Unit 1 • Nichols Unit 1 • Nichols Unit 2 • Nichols Unit 3

Steam Production — Coal • Harrington Unit 1 • Harrington Unit 2 • Harrington Unit 3 • Tolk Unit 1 • Tolk Unit 2

Other Production — Combustion Turbine • Cunningham Unit 3 • Cunningham Unit 4 • Jones Unit 3 • Jones Unit 4 • Maddox Unit 2 • Maddox Unit 3 • Quay County Unit 1

4 SPS's natural gas-fueled plants consist of 12 steam turbine units and

5 7 combustion turbines. SPS's coal-fueled power plants consist of 5 steam units.


RR 4 - Page 549 of 693 02358

1

SPS's Carlsbad Generating Station was retired on December 31, 2017 and

2

it has been dismantled. A major addition to the SPS generation fleet is the Hale

3

Wind Project. The Hale Wind Project began commercial operation in June 2019.

4

In addition to these SPS-owned facilities, SPS also makes use of four solar

5

generation facilities located in New Mexico.

6 Q. Are any units dedicated for peaking service?

7 A. Yes. The combustion turbines at Jones Units 3 and 4, Cunningham Units 3 and 4,

8

and Maddox Unit 2 are considered peaking units.

9 Q. Are any units used primarily for emergency situations?

10 A. Yes. Quay County and Maddox Unit 3 are designated primarily for emergency

11

use.


RR 4 - Page 550 of 693 02359

1 V. ENERGY SUPPLY O&M EXPENDITURES

2 Q. What are the types of O&M services and costs specifically associated with

3 SPS's Energy Supply business area?

4 A. SPS's Energy Supply business area provides a wide range of O&M services

5 necessary to support SPS's ability to provide electric service to its Texas and New

6 Mexico retail customers. Those services are provided to SPS directly through

7 SPS and through SPS's affiliate, Xcel Energy Services Inc. ("XES"). Within this

8 business area, SPS and XES employees have separate roles and responsibilities,

9 but work in coordination with each other and under the direction of the XES

10 Energy Supply business area management to provide various services, including:

11 Native and Affiliate Services:

12 • developing and executing projects for new generation and establishing 13 uniform technology, design and equipment standards for capital projects;

14 • implementation and maintenance of an Energy Supply Quality Assurance 15 and Quality Control Program and safety programs;

16 • plant engineering supporting the daily outage planning and execution, 17 reliability maintenance services, and plant equipment and performance 18 testing;

19 • maintaining technical resources on plant equipment to facilitate effective 20 maintenance;

21 • implementing compliance with NERC reliability standards;

22 • storm restoration activities; and

23 • ensuring SPS's continued compliance with environmental rules and 24 regulations including: air quality, water quality, hazardous and solid 25 waste, remediation, storage tanks, and emergency spill response.

26 Exclusively Affiliate Services:

27 • developing and maintaining Energy Supply project management processes 28 for capital projects and complex O&M projects;


RR 4 - Pa ge 551 of 693 02360

1 • overseeing Energy Supply capital construction projects;

2 • maintaining a working relationship with key suppliers of materials, 3 equipment, and engineering and construction services;

4 • providing environmental permitting and compliance support, training and 5 compliance assistance, auditing of compliance, and managing coal ash 6 contracts;

7 • developing, implementing, and supporting SPS's environmental leadership 8 strategy and associated policy initiatives;

9 • providing strategic asset management that delivers analysis and training 10 expertise in multiple areas, such as plant process chemistry and water 11 resources;

12 • managing the overhaul process to optimize outage planning and execution;

13 • overseeing and managing all testing activities and NERC standards 14 compliance through use of the Operating Model across the generating 15 fleet;

16 • developing and managing the capital budget, project management, Quality 17 Assurance/Quality Control programs, design control, and drawing control 18 processes; and

19 • providing management oversight and direction to the regional generation 20 organization, including the establishment of regional performance 21 indicators, fleet-wide improvement initiatives, and leadership of the 22 Energy Supply safety program.

23 Q. Are the services related to the Energy Supply business area reasonable and

24 necessary for SPS's operations?

25 A. Yes. The services are reasonable and necessary to ensure that SPS's generation

26 fleet, which is essential to providing electric service to SPS's customers, is safely

27 and reliably operated and maintained. For example, these services are necessary

28 to ensure that SPS's generation facilities remain in compliance with

29 environmental regulations and receive sufficient technical support. The Energy


RR 4 - Page 552 of 693 02361

1 Supply business area provides services that are required by all utilities, and

2 without which SPS would not be able to provide electric service to its customers.

3 Q. What amount is SPS requesting for native Energy Supply O&M?

4 A. The amounts included in Attachment DAL-RR-10 represent, at a total company

5 level, reasonable and necessary Energy Supply O&M costs incurred by SPS to

6 provide safe and reliable electric service to its Texas retail customers.

7 Q. What are the types of charges included in SPS's requested level of O&M

8 expenses related to Energy Supply?

9 A. Energy Supply-related O&M expenses include both native SPS costs and affiliate

10 charges. Native costs are those costs incurred directly by SPS associated with the

11 provision of electric service to customers. These costs include labor, materials,

12 and other non-fuel O&M costs. For example, the salaries of SPS employees are

13 native costs. Affiliate costs are those associated with services provided by XES

14 and the other Operating Companies4 to SPS. It is important to note that within the

15 Energy Supply business area, XES and SPS employees have separate roles and

16 responsibilities, but work in coordination with each other and under the direction

17 of the XES Energy Supply business area management to provide various services.

18 In other words, the services provided by SPS's affiliates are in addition to, and not

19 duplicative of, the services that SPS employees provide.

20 In addition, charges from SPS's affiliates must be provided "at cost," or

21 without profit, and the charges to SPS must be no higher than the charges to other

4 The Operating Companies are Northern States Power Company, a Minnesota corporation; Northern States Power Company, a Wisconsin corporation; Public Service Company of Colorado, a Colorado corporation; and SPS. Charges from the other Xcel Energy Operating Companies are generally related to emergency services, such as storm restoration activities.


RR 4 - Page 553 of 693 02362

1 Operating Companies for similar services. Ms. Schmidt provides additional

2 details regarding the methodology of charging affiliate costs to SPS from XES

3 and other affiliated entities. My testimony provides additional detail supporting

4 the costs of the Energy Supply affiliate classes.

5 Q. Are the O&M costs related to the Energy Supply business area necessary and

6 reasonable for SPS's operations?

7 A. Yes. As explained in more detail below, the Energy Supply business area

8 monitors its actual expenditures versus its budget. In addition, the costs for these

9 services include labor, materials, and other non-fuel O&M costs. SPS witness

10 Michael T. Knoll provides testimony explaining that SPS's labor costs are

11 reasonable. SPS witness Richard R. Schrubbe provides testimony regarding

12 explaining that SPS's pension and related benefits costs are reasonable. SPS

13 witness Gary J. O'Hara provides testimony explaining that the costs related to

14 sourcing and procurement of goods and services is reasonable, and Ms. Schmidt

15 provides testimony demonstrating that the methodology of billings for affiliated

16 labor and labor related overheads is reasonable.

17 Q During the fiscal year, does the Energy Supply business area monitor its

1 8 actual expenditures versus its budget?

19 A. Yes. Actual versus expected expenditures are monitored on a monthly basis by

20 management within each department of the Energy Supply business area.

21 Deviations are evaluated each month to ensure that costs are appropriate. In

22 addition, action plans are developed to mitigate variations in actual to budgeted


RR 4 - Page 554 of 693 02363

1 expenditures. These mitigation plans may either reduce or delay other

2 expenditures so that overall spending complies with the authorized budget.

3 Q. Are employees within the Energy Supply business area held accountable for

4 deviations from the budget?

5 A. Yes. All management employees in the Energy Supply business area have

6 specific budgetary targets that are measured on a monthly basis to ensure

7 adherence to the targets and provide for action plan development to address

8 variances.


RR 4 - Page 555 of 693 02364

1 VI. HALE WIND PROJECT O&M EXPENDITURES

2 Q. Is SPS proposing any adjustments to the Updated Test Year O&M?

3 A. Yes. The Updated Test Year O&M does not reflect the O&M expenses for the

4 Hale Wind Project, which began commercial operation in June 2019. The

5 adjustment requested for O&M expenditures for the Hale Wind Project is

6 $9,598,240 (total company). That amount is reflected in Attachment APF-RR-2

7 presented by Mr. Freitas as well as my Attachment DAL-RR-10, and it is

8 reasonable, necessary, and known and measurable.

9 Q. How was the amount included in the cost of service for the Hale Wind

1 0 Project O&M developed?

11 A. The Hale O&M costs in the cost of service reflect the cost of the SMWA with

12 Vestas of $7,686,240 (total company), as shown in Attachment APF-RR-6(CD)

13 for the year during the period that rates will be in effect. A copy of the SMWA is

14 provided as Attachment DAL-RR-2(V)(HS) to my testimony. The cost of service

15 also reflects the amount associated with SPS's land lease payments for the facility

16 under its Wind and Easement Lease Agreements ("Wind Lease Agreement") for

17 the year during the period that proposed rates will be in effect in the amount of

18 $1,912,000 (total company). A form of the Wind Lease Agreement is provided as

19 Attachment DAL-RR-3(HS) to my testimony. Because those amounts are based

20 in contract, they are known and measurable. In addition to these costs, there will

21 likely be O&M expenses in addition to these two categories that SPS intends to

22 request in future cases.


RR 4 - Page 556 of 693 02365

1 Q. Please provide a description of the Hale Wind Project.

2 A. The Hale Wind Project is a 478 megawatt ("MW") facility located in Hale

3 County, Texas. To develop the Hale Wind Project, SPS has installed 239 turbines

4 through a combination of Vestas model 2.0 MW V110 and 2.0 MW V116 wind

5 turbines. Site infrastructure includes access roads, foundations, electrical cable

6 collection systems, and a collection system substation. The generation output ties

7 into the SPP transmission system through a generation tie line from the Hale

8 Wind Project collector station to the interconnection tie breaker at the TUCO

9 substation (i.e., the SPP transmission grid point). The Commission granted SPS a

10 generation certificate of convenience and necessity in Docket 46936 that included

11 approval of the Hale Wind Project.5

12 Q. What is involved in the O&M of a wind project?

13 A. O&M activities associated with a wind project generally involve two categories of

14 maintenance: (1) scheduled; and (2) unscheduled. Scheduled maintenance

15 includes general preventative maintenance. Unscheduled maintenance stems

16 from the identification of operational issues from monitoring the wind turbines

17 and the subsequent repair of identified issues.

5 Application of Southwestern Public Service Company for Approval of Transactions with ESI Energy, LLC and Invenergy Wind Development North America LLC, to Amend a Certificate of Convenience and Necessity for Wind Generation Projects and Associated Facilities in Hale County, Texas and Roosevelt County, Nov Mexico, and for Related Approvals, Docket No. 46936, Final Order (May 25, 2018).


RR 4 - Page 557 of 693 02366

1 Q. Please provide an overview of SPS's plan for operating and maintaining the

2 Hale Wind Project.

3 A. SPS is using a combination of services provided by the Original Equipment

4 Manufacturer ("OEM") and internal personnel assigned to the Hale Wind Project

5 site. SPS has executed a SMWA with Vestas, the OEM.

6 Q. Why did SPS enter into an SMWA with Vestas?

7 A. Vestas is the OEM of the turbines used in building the Hale Wind Project. Xcel

8 Energy has found that using the OEM to perform O&M services offers several

9 benefits, including: (i) lowering the risk of claims of inadequate maintenance

10 during the warranty period; (ii) allowing Xcel Energy to readily obtain controls

11 and software updates that help maintain reliability; and (iii) allowing Xcel

12 Energy's teams to gain greater knowledge of technological advances by working

13 closely with the OEM, which leads to improved O&M on the turbines over their

14 useful lives. Vestas often provides O&M services to other wind projects,

15 providing SPS additional assurance that Vestas is highly qualified to do the O&M

16 work.

17 Q. What types of services will Vestas provide under the SMWA?

18 A. The SMWA obligates Vestas to perform warranty work as well as scheduled and

19 unscheduled maintenance. The SMWA covers warranty work for equipment,

20 including turbines, towers, and climb assists. Examples of warranty work include

21 replacement of failed parts such as bearings, electronic components, and the labor

22 associated with the replacement.


RR 4 - Page 558 of 693 02367

1 Vestas will also perform all maintenance, diagnostics, repair and

2 replacement services on the serviced equipment, including among other things,

3 performing gearbox borescopes, inspecting wind turbine blades, sampling

4 gearbox and hydraulic unit oil, checking tensioning of tower base section anchor

5 bolts and performing re-tensioning, monitoring and reporting any FAA lighting

6 outages, and repairing and maintaining climb assists at scheduled intervals.

7 Vestas is also required to maintain a suitable inventory of replacement and spare

8 parts for the wind turbines.

9 Q. Could SPS have provided internally the same services as Vestas is providing

10 through the SMWA?

1 1 A. No. SPS does not have employees trained in wind generation O&M, and SPS

12 does not currently have training programs to support such activities.

13 Q. How many internal staff will be assigned to work on Hale O&M?

14 A. There will be four internal staff that will provide plant management, engineering,

15 and administrative services to the Hale Wind Project, in addition to overseeing the

16 SMWA contractors. In addition, XES personnel will provide various support

17 services including providing technical service groups for assistance with

18 engineering issues, material and chemical analysis, grid reliability, equipment

19 analysis, environmental services, safety services, and site security.

20 Q. How does SPS and Xcel Energy work with the OEM to provide O&M

21 activities for a wind generation project?

22 A. Xcel Energy works with the OEM during all phases of the project construction

23 process and thereafter in the operation of the project. Xcel Energy staff monitors


RR 4 - Page 559 of 693 02368

1 and coordinates with those contractors to perform the O&M needed for the

2 facility. SPS staff coordinates on scheduled maintenance as well as on

3 responding to issues at the site. The contractor bears the responsibility for

4 reporting conditions at the site and any issues, and contractor will inform the

5 internal employees when an operations issue is identified.

6 In an instance where monitoring of SCADA data or other O&M-related

7 monitoring has revealed a potential operations issue, internal staff will direct the

8 external contractors to schedule a technician to go out to the turbine in question.

9 Depending upon the nature of the potential problem, the team that goes out to the

10 turbine may include both internal and external personnel. SPS works hand in hand

11 with the contractor to address the cause of the issue and fix it as timely as

12 possible.

13 Q. Is the SMWA and its terms reasonable and necessary for SPS's operations?

14 A. Yes, the SMWA is an essential part of the Hale Wind Project allowing for the

15 efficient operation of the facility. The SMWA was negotiated in an arm's length

16 transaction with Vestas.

17 Q. What type of plant management technology will the Hale Wind Project use?

18 A. The Hale Wind Project will use Energy Supply's Monitoring and Diagnostic

19 ("M&D") Center as described in Section XIII of my testimony.

20 Q. How will the Hale Wind Project be monitored?

21 A. Xcel Energy has staff on site Monday through Friday during normal business

22 hours, so if an issue arises during this time the staff can respond quickly. After

23 normal business hours, the SCADA system continues to be monitored remotely


RR 4 - Page 560 of 693 02369

1 by Vestas and personnel can be dispatched if an issue arises that requires an

2 immediate response. Turbines can also be turned off and restarted remotely if a

3 problem is observed and the turbine needs to be taken offline. Under both

4 emergency and non-emergency situations, however, the O&M response is just

5 like any other power plant: when you get an alarm, you go to the site and address

6 it as soon as practicable given the issue.

7 Q. In addition to the SMWA and internal staffing you have presented, are there

8 other O&M costs that SPS is requesting to recover regarding the Hale Wind

9 Project?

10 A. Yes. SPS is seeking recovery for payments to landowners pursuant to Wind Lease

11 Agreements.

12 Q. Please describe the Wind Lease Agreements associated with the Hale Wind

13 Project.

14 A. The transactions approved by the Commission in Docket 46936 included the

15 acquisition of Wind Lease Agreements in Hale County that enabled the

16 construction of the Hale Wind Project. The Wind Lease Agreements secure all

17 land rights necessary for all development activities including wind turbines,

18 overhead and underground electrical distribution, collection, transmission and

19 communication lines, electric transformers, electric substations, roads, wind

20 measurement equipment, and other ancillary facilities, as well as construction

21 activities and uses. Lease payments are made in accordance with formulas set

22 forth in the Wind Lease Agreements as among landowners located in defined

23 project areas.


RR 4 - Page 561 of 693 02370

1 Q. Are the Wind Lease Agreements and their terms reasonable and necessary

2 for SPS's operations?

3 A. Yes, the Wind Lease Agreements are an essential element allowing for the

4 construction and operation of the Hale Wind Project. Each was negotiated in an

5 arm's length transaction with landowners.

6 Q. Does Xcel Energy have experience with other wind project O&M?

7 A. Yes. Xcel Energy has wind farm O&M experience through multiple, successful

8 company-owned wind projects at its other Operating Companies.6 In total, by the

9 end of 2019 Xcel Energy expects to be operating 1,127 turbines with a nameplate

10 capacity of 2,200 MW, not including the Hale Wind Project.

11 Q. Has SPS applied the knowledge and experience that Xcel Energy has gained

12 from wind projects in other jurisdictions to its plan for operating and

13 maintaining the Hale Wind Project?

14 A. Yes. Xcel Energy and SPS applied the best practices learned from Xcel Energy's

15 experience at those wind farms to SPS's O&M plan for the Hale Wind Project.

16 Based on this experience, SPS believes that its O&M activities and requested

17 amount for the Hale Wind Project are reasonable, necessary, and known and

18 measurable.

6 Xcel Energy's electric operating companies are: Northern States Power Company - Minnesota, Northem States Power Company — Wisconsin, Public Service Company, Public Service Company Colorado and SPS.


RR 4 - Page 562 of 693 02371

1 vII. AFFILIATE CLASSES SPONSORED

2 Q. Earlier in your testimony, you referred to "affiliate classes." What do you

3 mean by the terms "affiliate classes" or "affiliate classes of services"?

4 A. A portion of SPS's costs reflects charges for services provided by a supplying

5 affiliate, specifically XES or one of the Operating Companies. These charges

6 have been grouped into various affiliate classes, or aggregations of charges, based

7 upon the business area, organization, or department that provided the service or,

8 in a few instances, the accounts that captured certain costs. In her direct

9 testimony, Ms. Schmidt provides a detailed explanation of how the affiliate

10 classes were developed and are organized for this case.

11 Q. Which affiliate classes do you sponsor?

12 A. 1 sponsor the ES Projects, ES Environmental, ES Performance Optimization, ES

13 VP Energy Supply, and ES VP Operations classes of affiliate services.


RR 4 - Page 563 of 693 02372

1 VIII. AFFILIATE EXPENSES FOR THE ES PROJECTS CLASS OF 2 SERVICES

3 A. Summary of Affiliate Expenses for the ES Projects Class of 4 Services

5 Q. Where does the ES Projects affiliate class fit into the overall affiliate

6 structure?

7 A. Attachment MLS-RR-6 to Ms. Schmidt's direct testimony provides a list and a

8 pictorial display of all affiliate classes, dollar amounts for those classes, and

9 sponsoring witness for each class. As seen on that attachment, the ES Projects

10 affiliate class was part of the Energy Supply business area during the Updated

11 Test Year. Attachment DAL-RR-1 to my testimony is an organization chart

12 showing the Energy Supply organization.

13 Q. What services are grouped into the ES Projects affiliate class?

14 A. The services that are grouped into the ES Projects affiliate class are:

15 • Texas and New Mexico regional capital engineering;

16 • design and document services; and

17 • construction and project services.

18 Q. What is the dollar amount of the Updated Test Year XES charges that SPS

19 requests, on a total company basis, for the ES Projects affiliate class?

20 A. The following table summarizes the dollar amount of the estimated Updated Test

21 Year XES charges for the ES Projects affiliate class. I will update the table below

22 as part of SPS's 45-day case update filing to reflect the actual Updated Test Year

23 costs for the ES Projects affiliate class.


RR 4 - Page 564 of 693 02373

1 Table DAL-RR-2

Requested Amount of XES Class Expenses Billed to SPS (Total

Company)

Class of Services Total XES

Class Expenses

Requested Amount

% Direct Billed

%

Allocated

ES Projects $3,251,362 $690,333 87.57% 12.43%

Total XES Class Expenses

Requested Amount of XES Class Expenses Billed to SPS (Total Company)

% Direct Billed

% Allocated

Dollar amount of total Updated Test Year expenses that XES charged to all Xcel Energy companies for the services provided by this affiliate class. This is the amount from Column E in Attachment DAL-RR-A.

Requested dollar amount of XES expenses to SPS (total company) for this affiliate class after exclusions and pro forma adjustments. This is the amount from Column K in Attachment DAL-RR-A.

The percentage of SPS's requested XES expenses (total company) for this class that were billed 100% to SPS.

The percentage of SPS's requested XES expenses (total company) for this class that were allocated to SPS.


RR 4 - Page 565 of 693 02374

1 Q. Please describe the attachments that support the information provided on

2 Table DAL-RR-2.

3 A. There are four attachments to my testimony that present information about the

4 requested SPS affiliate expenses for the ES Projects affiliate class.

5 Attachment DAL-RR-A: Provides a summary of the affiliate expenses

6 for this class during the Updated Test Year. The summary starts with the total of

7 the XES expenses to SPS for the services provided by this affiliate class and ends

8 with the requested dollar amount of XES expenses to SPS (total company) for this

9 affiliate class after exclusions and pro forma adjustments. The columns on this

10 attachment provide the following information.

Column A — Line No. Lists the Attachment line numbers.

Column B — Affiliate Class Lists the affiliate class.

Column C —

Column E —

Column F —

Billing Method (Cost Center)

Total XES Billings for Class to all Legal Entities (FERC Acct. 400-935)

XES Billings for Class to all Legal Entities Except for SPS (FERC Acct. 400-935)

Shows the billing method that XES uses to charge the expenses to the affiliates, and the billing method short title. In her direct testimony, Ms. Schmidt explains the billing methods and defines the codes.

Shows the allocation method applicable to the billing method (cost center).

Shows XES billings to all legal entities for the affiliate class.

Shows XES billings to all legal entities other than SPS for the affiliate class.

Column D — Allocation Method


RR 4 - Page 566 of 693 02375

Column L —

Shows XES billings to SPS (total company) for the affiliate class.

Shows the total dollars to be excluded from Column G. Exclusions reflect expenses not requested, such as expenses not allowed or other below-the-line items.

Shows XES billings to SPS (total company), for the affiliate class, after the exclusions shown in Column H. The dollar amount in Column I is Column G plus Column H.

Shows the total dollar amount of pro forma adjustments to the dollar amount in Column I. Pro forma adjustments reflect revisions for known and measurable changes to the Updated Test Year expenses. Shows the requested amount (total company) for the affiliate class. The dollar amount in Column K is Column I plus Column J.

Column G — XES Billings for Class to SPS (Total Company) (FERC Acct. 400-935)

Column H — Exclusions

Column I — Per Book

Column J — Pro Formas

Column K — Requested Amount (Total Company)

Percentage of class Shows the percentage of affiliate class charges charges billed using the cost center.

1 In her direct testimony, Ms. Schmidt provides a consolidated summary of

2 affiliate expenses billed to SPS for all classes during the Test Year and Updated

3 Test Year.

4 Attachment DAL-RR-B(CD): Provides the detail of the XES expenses

5 for the ES Projects affiliate class that are summarized on Attachment DAL-RR-A.

6 The detail shows the XES expenses billed to SPS for the ES Projects affiliate

7 class, itemized by the amount with each expense listed by individual activity and


RR 4 - Page 567 of 693 02376

Column B — Legal Entity Receiving XES Expenses

Column C —

Column D —

Column E —

Column F —

Affiliate Class

Cost Element

Activity

Billing Method (Cost Center)

billing method (cost center). When summed, these amounts tie to the amounts

shown on Attachment DAL-RR-A and the detail regarding the expenses is

organized to support that attachment. Specifically, the columns on this attachment

provide the following information.


Column G — FERC Account

Shows the legal entity (Xcel Energy or one of its subsidiaries) that received the XES expense.

Lists the affiliate class.

Provides the cost element number

Provides a short title for the activity.

Identifies the billing method and short title. In her direct testimony, Ms. Schmidt explains the billing methods and defines the codes.

Shows the FERC Account in which the expense was recorded.

Shows the itemized amount of the listed XES expense that was billed to all legal entities.

Shows the itemized amount of the listed XES expense that was billed to all legal entities other than SPS.

Shows the itemized amount of the listed XES expense that was billed to SPS. Therefore the sum of this column provides total billings to SPS and ties to the total dollar amount for the affiliate class in Column G of Attachment DAL-RR-A.

Column H — XES Billings for Class to All Legal Entities (FERC Acct. 400-935)

Column I — XES Billings for Class to All Legal Entities Except SPS (FERC Acct. 400-935)

Column J — XES Billings for Class to SPS (Total Company) (FERC Acct. 400-935)


RR 4 - Page 568 of 693 02377

Column K — Exclusions

Column L — Per Book

Column M — Pro Formas

Column N — Requested Amount (Total Company)

Shows the total dollars excluded from Column J. The total dollar amount for the affiliate class in Column K ties to the total dollar amount for the affiliate class in Column H of Attachment DAL-RR-A.

Shows XES billings to SPS (total company), for the affiliate class after the exclusions shown in Column K. The dollar amount in Column L is Column J plus Column K. The total dollar amount for the affiliate class in Column L ties to the total dollar amount for the affiliate class in Column I of Attachment DAL-RR-A.

Shows the dollar amount of pro forma adjustments to the dollar amount in Column L. The total dollar amount for the affiliate class in Column M ties to the total dollar amount for the affiliate class in Column J of Attachment DAL-RR-A. Shows the requested amount (total company) for the affiliate class. The dollar amount in Column N is Column L plus Column M. The total dollar amount for the affiliate class in Column N ties to the total dollar amount for the affiliate class in Column K of Attachment DAL-RR-A.

1 Ms. Schmidt also provides a consolidated summary of this information for

2 all affiliate classes during the Test Year and the Updated Test Year.

3 Attachment DAL-RR-C: Both Attachments DAL-RR-A and

4 DAL-RR-B(CD) show exclusions to the XES expenses billed to SPS for the ES

5 Projects affiliate class (Attachment DAL-RR-A, Column H; Attachment DAL-

6 RR-B(CD), Column K). Attachment DAL-RR-C provides detail about those


RR 4 - Page 569 of 693 02378

1 exclusions listed on Attachments DAL-RR-A and DAL-RR-B(CD). The columns

2 on Attachment DAL-RR-C provide the following information.



Column C — FERC Account Identifies the FERC Account for the expense that has been excluded.

Column D — Explanations for Provides a brief rationale for the Exclusions exclusion.

Column E — Exclusions (Total Shows the dollar amount of the Company) exclusion.

3 In her direct testimony, Ms. Schmidt describes the calculations underlying

4 the exclusions.

5 Attachment DAL-RR-D: Both Attachments DAL-RR-A and

6 DAL-RR-B(CD) show pro forma adjustments to SPS's per book expenses for the

7 ES Projects affiliate class (Attachment DAL-RR-A, Column J; Attachment DAL-

8 RR-B(CD), Column M). Attachment DAL-RR-D provides information about

9 those pro forma adjustments shown on Attachments DAL-RR-A and DAL-RR-

1 0 B(CD). The columns on Attachment DAL-RR-D provide the following

1 1 information.



Column C — FERC Account Identifies the FERC Account affected by the pro forma adjustment.


RR 4 - Page 570 of 693 02379

Column D — Explanations for Pro Provides a brief rationale for the pro Formas forma adjustment.

Column E — Sponsor Identifies the witness or witnesses who sponsor the pro forma adjustment.

Column F — Pro Formas (Total Shows the dollar amount of the pro Company) forma adjustment.

1 Q. Does XES bill its expenses for the ES Projects affiliate class to SPS in the

2 same manner as it bills other affiliates for those expenses?

3 A. Yes. As discussed by Ms. Schmidt, XES uses the same method for billing and

4 allocating costs to affiliates other than SPS that it uses to bill and allocate those

5 costs to SPS.

6 Q. Are there any exclusions to the XES billings to SPS for the ES Projects

7 affiliate class?

8 A. No. As I mentioned earlier, exclusions reflect expenses not requested, such as

9 expenses not allowed or other below-the-line items. Exclusions are shown on

10 Attachment DAL-RR-A, Column H, and on Attachment DAL-RR-B(CD),

11 Column K. The details for the exclusions are provided in Attachment DAL-RR-

12 C. Ms. Schmidt describes how the exclusions were calculated. In SPS's 45-day

13 case update, I will present an updated Attachment DAL-RR-C that will provide

14 actual exclusions to replace any estimated exclusions included my original

15 attachment.


RR 4 - Pa ge 571 of 693 02380

1 Q. Are there any pro forma adjustments to SPS's per book expenses for the ES

2 Projects affiliate class?

3 A. Yes. As I mentioned earlier, pro forma adjustments are revisions to Updated Test

4 Year expenses for known and measurable changes. Pro forma adjustments are

5 shown on Attachment DAL-RR-A, Column J, and on Attachment DAL-RR-

6 B(CD), Column M. The details for the pro forma adjustments, including the

7 witness or witnesses who sponsor each pro forma adjustment, are provided in

8 Attachment DAL-RR-D. Given the time of SPS's initial filing, only the first nine

9 months of the Updated Test Year have completed the full pro forma adjustment

10 review process. In SPS's 45-day case update, I will present an updated

11 Attachment DAL-RR-D that will complete the full pro forma adjustment review

12 process for the last three months of the Updated Test Year.

13 Q. Attachment DAL-RR-D shows that you sponsor pro forma adjustments for

14 expenses for the ES Projects affiliate class during the first nine months of the

15 Updated Test Year that result in a net decrease for the ES Projects affiliate

16 class of $803.19 Please explain the adjustments.

17 A. The adjustments that I sponsor remove payroll costs that have been adjusted to

18 remove amounts for life events (a decrease of $713.89) and costs not benefitting

19 SPS (a decrease of $89.30).


RR 4 - Page 572 of 693 02381

1 B. The ES Proiects Class of Services are Necessary Services

2 Q. Are the services that are grouped in the ES Projects affiliate class necessary

3 for SPS's operations?

4 A. Yes. The services grouped in the ES Projects affiliate class are necessary to

5 ensure that SPS's capital projects are managed efficiently and safely and on

6 schedule. They are functions required by all utilities and without which SPS

7 would not be able to provide electric service to its customers.

8 Q. What are the specific services that are provided to SPS by the ES Projects

9 affiliate class?

1 0 A. The specific services that are provided to SPS by the ES Projects affiliate class

11 are:

12 • developing and maintaining a uniform Energy Supply project 13 management process, including supporting tools, and the design and 14 engineering process;

15 • managing capital projects, and executing larger, more complex O&M 16 projects;

17 • developing and executing projects for new generation (including 18 renewable and innovative technologies), establishing uniform 19 technology, design, and equipment standards for capital projects, 20 developing and managing an Energy Supply process for custody, care, 21 and control of drawing and engineering records;

22 • coordinating development, implementation and maintenance of an 23 Energy Supply Quality Assurance and Quality Control Program; and

24 • maintaining a working relationship with key suppliers of materials, 25 equipment, and engineering and construction services.


RR 4 - Page 573 of 693 02382

1 Q. Are any of the ES Projects class of services that are provided to SPS

2 duplicated elsewhere in XES or in any other Xcel Energy subsidiary such as

3 SPS itself?

4 A. No. Within XES, none of the services grouped in the ES Projects affiliate class

5 are duplicated elsewhere. No other Xcel Energy subsidiary performs these

6 services for the Operating Companies. In some cases the plant engineers on small

7 capital projects will conduct some of the services that ES Projects typically

8 perform. This is not a duplication of service; rather it utilizes the appropriate

9 resource for the project. It is more efficient for plant engineers to manage

10 commodity projects due to their physical location. Although there are both XES

11 and SPS employees in the ES Projects organization, the SPS employees do not

12 perform the same activities as the XES employees and they have separate

13 responsibilities and roles. The services provided by the SPS employees are not

14 duplicative of the services provided by XES, although they work in coordination

15 with and under the direction of the XES Energy Supply management. In addition,

16 SPS does not perform these services for itself.

17 Q. Do SPS's Texas retail customers benefit from the services that are part of the

1 8 ES Projects class of services?

19 A. Yes. The services of the ES Projects affiliate class benefit SPS's customers in

20 many ways. For example, the ES Projects class develops and deploys capital

21 budget and project management processes that guide funding decisions, minimize

22 project risks, and ensure delivery of targeted value. Working with the plants and

23 other support organizations within Energy Supply allows capital spending to be


RR 4 - Page 574 of 693 02383

1 optimized to achieve the best overall plant performance. From July 1, 2017

2 through March 31, 2019 (i.e., the first day after the end of the period for which

3 capital additions were approved in Docket No. 475277 through the end of the Test

4 Year), Energy Supply has completed capital projects totaling $62,344,8488 (total

5 company) for SPS, which have had the rigor of the above noted budget and

6 project management processes applied to them. Overall capital project cash flow

7 variance (i.e., actual to budget and forecast) was within the acceptable target

8 range, which results in improved cash management and ensures that capital

9 project schedules are maintained, thus minimizing the potential of cost overruns.

10 This group also performs engineering designs for small to mid-sized capital

11 projects and is the primary interface with third-party contractors and vendors used

12 on plant capital projects. Some O&M support is also provided for the plants with

13 the most significant work being drafting, maintaining, and updating plant

14 drawings.

15 C. The ES Projects Class of Services are Provided at a Reasonable 16 Cost

17 Q. Are the costs of the ES Projects class of services reasonable?

18 A. Yes. The costs of the ES Projects class of services are reasonable. XES provides

19 the services and functions in the ES Projects class of services on a consolidated

20 basis for multiple Xcel Energy legal entities. As a result, SPS benefits from

7 Application of Southwestern Public Sen'ice Company for Authority to Change Rates, Docket

No. 47527, Order (Dec. 10, 2018).

8 Please refer to the Direct Testimony of SPS witness Mark Lytal, Attachment ML-RR-1. Mr. Lytal's Attachment ML-RR-2 provides the Energy Supply capital projects placed in service during the Update Period, which have also had the rigor of the above noted budget and project management processes applied to them.


RR 4 - Page 575 of 693 02384

1 sophisticated services provided by a pool of talented professionals, the

2 consolidated costs of which are shared. The economies of scale inherent in this

3 system result in reasonable costs for SPS for these services.

4 1. Additional Evidence

5 Q. Is there any additional evidence that supports your opinion that the costs of

6 the ES Projects affiliate class are reasonable?

7 A. Yes. Of the estimated Updated Test Year costs for the ES Projects class,

8 approximately 89.73% are compensation and benefits costs for XES personnel.

9 Mr. Knoll and Mr. Schrubbe establish that the level of Xcel Energy's

10 compensation and benefits is reasonable and necessary.

11 2. Budget Planning

12 Q. Is a budget planning process applicable to the ES Projects class of affiliate

13 costs?

14 A. Yes. Annual O&M budgets are created for the ES Projects organization, which

15 includes the ES Projects class of affiliate costs, using guidelines developed at the

16 corporate level. Each manager within the ES Projects organization carefully

17 reviews historical spend information, identifies changes that will be coming in the

18 future, and analyzes the costs associated with those changes prior to submitting a

19 proposed budget. The budgeting process is discussed in more detail by SPS

20 witness Adam R. Dietenberger.


RR 4 - Page 576 of 693 02385

1 Q. During the fiscal year, does the ES Projects organization monitor its actual

2 expenditures versus its budget?


4 management within each department. Deviations are evaluated each month to

5 ensure that costs are appropriate. In addition, action plans are developed to

6 mitigate variations in actual to budgeted expenditures. These mitigation plans

7 may either reduce or delay other expenditures so that the revised budget supports

8 the authorized budget. If authorized budget adjustments are required, they are

9 identified and approved at an appropriate level of management.

10 Q. Are employees within the ES Projects organization held accountable for

1 1 deviations from the budget?

12 A. Yes. All management employees in the ES Projects organization have specific

13 budgetary goals that are incorporated into their performance evaluations.

14 Performance is measured on a monthly basis to ensure adherence to the goals and

15 provide for action plan development to address variances. All ES Projects

16 employees are required to manage their expenses to support the budgetary goals

17 established by their manager. Failure to meet these performance targets will

18 affect their performance evaluation and overall compensation.


RR 4 - Page 577 of 693 02386

1 3. Cost Trends

2 Q. Please state the dollar amounts of the actual per book charges from XES to

3 SPS for the ES Projects class of services for the three fiscal years preceding

4 the end of the Updated Test Year and the estimated per book charges for the

5 estimated Updated Test Year.

6 A. The following table shows, for the fiscal years 2016, 2017, and 2018 (calendar

7 years), the actual per book and, for the Updated Test Year, the estimated per book

8 affiliate charges (Column I on Attachment DAL-RR-A) from XES to SPS for the

9 services grouped in the ES Projects affiliate class:

10 Table DAL-RR-3

ES Projects (Per Book) Charges Over Time

Class of Services 2016 2017 2018

Updated Test Year

(Estimated)

ES Projects $1,757,130 $1,346,933 $611,453 $698,517

1 1 Q. What are the reasons for this trend?

12 A. The decrease in costs from 2016 to 2018 reflects a reduction in headcount. The

13 increase from 2018 to the Updated Test Year reflects additional labor charges.


RR 4 - Page 578 of 693 02387

1 4. Staffing Trends

2 Q. Please provide the staffing levels for the ES Projects class of services for the

3 three fiscal years preceding the end of the Updated Test Year and the

4 Updated Test Year.

5 A. The following table shows, for the fiscal years 2016, 2017, and 2018 (calendar

6 years) and for the Updated Test Year, the average of the end of month staffing

7 levels for the ES Projects class of services.

8 Table DAL-RR-4

Average End of Month # of Staff

Class of Services 2016 2017 2018 Updated Test Year

(Estimated)

ES Projects 122 121 111 108

9 Q. What are the reasons for this trend?

10 A. The average staffing levels from 2016 through the Updated Test Year have

11 dropped due to attrition. Some of these roles were filled with staff augmentation

12 (contractors), and several positions are open and seeking qualified candidates.

13 Some reductions were made as jobs were consolidated based on workloads.

14 5. Cost Control and Process Improvement Initiatives

15 Q. Separate from the budget planning process, does the ES Projects affiliate

16 class take any steps to control its costs or to improve its services?

17 A. Yes. ES Projects leverages requests for proposal for multiple projects together to

18 negotiate better prices on materials and construction costs. ES Projects also

19 contracts with the same engineers across the production fleet to perform similar

20 projects, which lowers costs and improves the quality due to familiarization and


RR 4 - Page 579 of 693 02388

1 repetition of tasks. Additionally, the Energy Supply affiliate classes have a

2 foundation of Xcel Energy's policies and procedures, which stress the importance

3 of cost control and continuous improvement.

4 D. The Costs for the ES Projects Class of Services are Priced in a 5 Fair Manner

6 Q. For those costs that XES charges (either directly or through use of an

7 allocation) to SPS for the ES Projects class of services, does SPS pay any

8 more for the same or similar service than does any other Xcel Energy

9 affiliate?

10 A. No. The XES charges to SPS for any particular service are no higher than the

11 XES charges to any other Xcel Energy affiliate. The costs charged for particular

12 services are the actual costs that XES incurred in providing those services to SPS.

13 A single, specific allocation method, rationally related to the cost drivers

14 associated with the service being provided, is used with each cost center (billing

15 method). In her direct testimony, Ms. Schmidt discusses the selection of billing

16 methods and XES's method of charging for services in more detail.

17 Q. How are the costs of the ES Projects affiliate class billed to SPS?

18 A. My Attachment DAL-RR-B(CD) shows all of the costs in this class broken out by

19 activity and, in conjunction with Column C in my Attachment DAL-RR-A, shows

20 the billing method associated with each activity. My Attachment DAL-RR-A

21 shows the allocation method (Column D) associated with each billing method

22 (Column C) used in the affiliate class.

23 In SPS's 45-day case update, I will present updated Attachments DAL-

24 RR-A and DAL-RR-B(CD) so that the entries for the last three months of the


RR 4 - Page 580 of 693 02389

1 Updated Test Year provide actual data and conform to the information provided

2 for the first nine months. In the event the predominant billing methods and

3 associated allocation methods for the ES Projects affiliate O&M expenses on my

4 updated Attachments DAL-RR-A and DAL-RR-B(CD) differ from those

5 discussed below, I will explain those differences in supplemental testimony in

6 SPS's 45-day case update filing.

7 Q. What are the predominant allocation methods used for billing the costs that

8 SPS seeks to recover for the ES Projects affiliate class of services?

9 A. All of the requested XES charges to SPS for this class were charged using one of

10 the following billing allocation methods:

11 • Direct Billing — 87.57% of XES charges to SPS — $604,548.83;

12 • Electric Production Plant/Electric Transmission Plant/Electric Distribution 13 Plant/Gas Transmission Plant/Gas Distribution Plant — 9.33% of XES 14 charges to SPS - $64,393.65; and

15 • MWH Generation — 3.10% of XES charges to SPS — $21,390.39.

16 Q. Why is the "Direct Billing" method appropriate for assigning the costs

17 captured in the cost centers that use that billing method?

18 A. For the cost centers that are assigned using the "Direct Billing" method, the costs

19 normally reflect work that was performed specifically for SPS only. In some

20 cases, however, the direct billing occurred after the application of an off-line

21 allocator that tracks the relevant cost drivers. In either situation, the cost centers

22 charged using the "Direct Billing" method are appropriate because the assignment

23 of costs is in accordance with the distribution of benefits for the services received.

24 For example, the costs related to labor costs related to specific SPS plants were

25 assigned using the "Direct Billing" method. The cost of these services benefited


RR 4 - Page 581 of 693 02390

1 SPS, the work was performed specifically for SPS alone, and one of the cost

2 drivers is boiler work. Thus, the "Direct Billing" method is appropriate because it

3 assigns costs in accordance with cost causation and benefits received. For the

4 cost centers that assign costs using Direct Billing, the per unit amounts charged by

5 XES to SPS are no higher than the unit amounts billed by XES to other affiliates

6 for the same or similar services and represent the actual costs of the services.

7 Q. Why is it appropriate to allocate costs based upon the "Electric Production

8 Plant/Electric Transmission Plant/Electric Distribution Plant/Gas

9 Transmission Plant/Gas Distribution Plant" method for the costs captured in

1 0 the cost centers that use that allocation method?

11 A. For the cost center charged using the "Electric Production Plant/Electric

12 Transmission Plant/Electric Distribution Plant/Gas Transmission Plant/Gas

13 Distribution Plant" method as the allocator, the costs are driven by environmental

14 services needed. For example, the labor and non-labor costs dedicated to air

15 quality, renewable energy, innovative technology and climate change, developing

16 corporate compliance strategy, regulatory agency interaction (both at the federal

17 and/or state level), permitting and compliance reporting, waste management,

18 combustion byproducts management, environmental compliance auditing,

19 providing support to the Environmental Council, and assisting with environmental

20 communications strategies, which are collected in Cost Center 200181, are

21 assigned using this allocation method. Thus, allocating costs based on the

22 environmental services used is appropriate for the allocation of costs to affiliates

23 because it allocates costs for the services in accordance with cost causation and

24 the distribution of the benefits of the services received. For the cost centers that


RR 4 - Page 582 of 693 02391

1 assign costs based upon this allocation method, the per unit amounts charged by

2 XES to SPS as a result of the application of this allocation method are no higher

3 than the unit amounts billed by XES to other affiliates for the same or similar

4 services and represent the actual costs of the services.

5 Q. Why is it appropriate to allocate costs based upon the "MW11 Generation"

6 method for the costs captured in the cost centers that use that billing

7 method?

8 A. The costs in the ES Projects class that are associated with engineering labor at

9 SPS generating facilities are assigned using the "MWH Generation" method

10 because such costs are directly related to the support of power plants. Thus,

11 allocating costs based on the MWH Generation method is appropriate for the

12 allocation of costs to affiliates because it allocates costs for the services in

13 accordance with cost causation and the distribution of the benefits of the services

14 received. For example, Cost Center 200135, which uses the MWH Generation

15 method as the allocator, captures the costs associated with labor and non-labor

16 costs of performance analysis, specialists, and analytical services provided to the

17 Operating Companies' generation facilities. For the cost centers that assign costs

18 based upon this billing method, the per unit amounts charged by XES to SPS as a

19 result of the application of this billing method are no higher than the unit amounts

20 billed by XES to other affiliates for the same or similar services and represent the

21 actual costs of the services.


RR 4 - Page 583 of 693 02392

1

2 IX. AFFILIATE EXPENSES FOR THE ES ENVIRONMENTAL 3 CLASS OF SERVICES

4 A. Summary of Affiliate Expenses for the ES Environmental Class of 5 Services

6 Q. Where does the ES Environmental affiliate class fit into the overall affiliate

7 structure?

8 A. Attachment MLS-RR-6 to Ms. Schmidt's direct testimony provides a list and a

9 pictorial display of all affiliate classes, dollar amounts for those classes, and

10 sponsoring witness for each class. As seen on that attachment, the ES

11 Environmental affiliate class was part of the Energy Supply business area during

12 the Updated Test Year. Attachment DAL-RR-1 to my testimony is an

13 organization chart showing the Energy Supply organization.

14 Q. What services are grouped into the ES Environmental affiliate class?

15 A. The services that are grouped into the ES Environmental affiliate class include:

16 • Environmental Services Air and Water;

17 • Environmental Services Waste Remediation;

18 • Environmental Policy and Services;

19 • Chemistry and Water Resources; and

20 • Environmental Services Audit.

21 Q. What is the dollar amount of the Updated Test Year XES charges that SPS

22 requests, on a total company basis, for the ES Environmental affiliate class?

23 A. The following table summarizes the dollar amount of the estimated Updated Test

24 Year XES charges for the ES Environmental affiliate class. I will update the table


RR 4 - Page 584 of 693 02393

below as part of SPS's 45-day case update filing to reflect the actual Updated Test

Year costs for the ES Environmental affiliate class.

Table DAL-RR-5

Requested Amount of XES Class Expenses Billed to SPS (Total

Company)

Class of Services Total XES

Class Expenses

Requested Amount

% Direct Billed

% Allocated

ES Environmental $8,081,240 $1,678,242 86.75% 13.25%

Total XES Class Expenses

Requested Amount of XES Class Expenses Billed to SPS (Total Company)

% Direct Billed

% Allocated

Dollar amount of total Updated Test Year expenses that XES charged to all Xcel Energy companies for the services provided by this affiliate class. This is the amount from Column E in Attachment DAL-RR-A.

Requested dollar amount of XES expenses to SPS (total company) for this affiliate class after exclusions and pro forma adjustments. This is the amount from Column K in Attachment DAL-RR-A.

The percentage of SPS's requested XES expenses (total company) for this class that were billed 100% to SPS.

The percentage of SPS's requested XES expenses (total company) for this class that were allocated to SPS.


RR 4 - Page 585 of 693 02394

1

2

3

1 Q. Please describe the attachments that support the information provided on

2 Table DAL-RR-5.

3 A. There are four attachments to my testimony that present information about the

4 requested SPS affiliate expenses for the ES Environmental affiliate class. I

5 explained these attachments in detail previously in Section VIII.A of my

6 testimony.

7 Q. Does XES bill its expenses for the ES Environmental affiliate class to SPS in

8 the same manner as it bills other affiliates for those expenses?

9 A. Yes. As discussed by Ms. Schmidt, XES uses the same method for billing and

10 allocating costs to affiliates other than SPS that it uses to bill and allocate those

11 costs to SPS.

12 Q. Are there any exclusions to the XES billings to SPS for the ES

13 Environmental affiliate class?

14 A. No. Exclusions are shown on Attachment DAL-RR-A, Column H, and on

15 Attachment DAL-RR-B(CD), Column K. The details for the exclusions are

16 provided in Attachment DAL-RR-C. Ms. Schmidt describes how the exclusions

17 were calculated. In SPS's 45-day case update, I will present an updated

18 Attachment DAL-RR-C that will provide actual exclusions to replace any

19 estimated exclusions included in my original attachment.

20 Q. Are there any pro forma adjustments to SPS's per book expenses for the ES


22 A. Yes. As I mentioned earlier, pro forma adjustments are revisions to Updated Test

23 Year expenses for known and measurable changes. Pro forma adjustments are


RR 4 - Page 586 of 693 02395

1 shown on Attachment DAL-RR-A, Column H, and on Attachment DAL-RR-

2 B(CD), Column K. The details for the pro forma adjustments, including the

3 witness or witnesses who sponsor each pro forma adjustment, are provided in

4 Attachment DAL-RR-D. Given the time of SPS's initial filing, only the first nine

5 months of the Updated Test Year have completed the full pro forma adjustment

6 review process. In SPS's 45-day case update, I will present an updated

7 Attachment DAL-RR-D that will complete the full pro forma adjustment review

8 process for the last three months of the Updated Test Year.

9 Q. Attachment DAL-RR-D shows that you sponsor pro forma adjustments for

10 expenses for the ES Environmental affiliate class during the first nine

11 months of the Updated Test Year that result in a net decrease for the ES

12 Environmental affiliate class of $60.88. Please explain the adjustments.

13 A. The adjustments that I sponsor remove amounts for life events (a decrease of

14 $60.88).

15 B. The ES Environmental Class of Services are Necessary Services

16 Q. Are the services that are grouped in the ES Environmental affiliate class

17 necessary for SPS's operations?

18 A. Yes. The services grouped in the ES Environmental affiliate class are necessary

19 to ensure that the plant facilities remain in compliance with environmental

20 regulations. The personnel within this class perform tasks such as seeking

21 amendments and obtaining permits required for existing and new facilities. They

22 are functions required by all utilities and without these functions SPS would be

23 unable to provide electric service to its customers.


RR 4 - Page 587 of 693 02396

1 Q. What are the specific services that are provided to SPS by the ES


3 A. The specific services that are provided to SPS by the ES Environmental affiliate

4 class are:

5 • ensuring SPS's continued compliance with environmental rules and 6 regulations, including: air quality, water quality, hazardous and solid 7 waste, remediation, storage tanks, and emergency spill response;

8 • managing the coal ash contracts with contractors;

9 • providing environmental permitting and compliance support, training 10 and compliance assistance services, and auditing of compliance with 11 environmental regulations; and

12 • developing, implementing, and supporting SPS's environmental 13 leadership strategy and associated policy initiatives.

14 Q. Are any of the ES Environmental class of services that are provided to SPS

15 duplicated elsewhere in XES or in any other Xcel Energy subsidiary such as

16 SPS itself?

17 A. No. Within XES, none of the services grouped in the ES Environmental affiliate

18 class are duplicated elsewhere. No other Xcel Energy subsidiary performs these

19 services for the Operating Companies. In addition, SPS does not perform these

20 services for itself. Although there are both XES and SPS employees in the Energy

21 Supply organization, the SPS employees do not perform the same activities as the

22 XES employees and they have separate responsibilities and roles. The services

23 provided by the SPS employees are not duplicative of the services provided by

24 XES, although they work in coordination with and under the direction of the XES

25 management.


RR 4 - Page 588 of 693 02397

1 Q. Do SPS's Texas retail customers benefit from the services that are part of the

2 ES Environmental class of services?

3 A. Yes. The services of the ES Environmental affiliate class benefit SPS's

4 customers in many ways. For example, the costs associated with the ES

5 Environmental class are incurred to ensure that SPS complies with all federal,

6 state, and local environmental rules and regulations. SPS benefits from

7 sophisticated environmental services provided to the Energy Supply organization,

8 the consolidated costs of which are shared. The economies of scale inherent in

9 this system result in reasonable costs for SPS for these services.

10 C. The ES Environmental Class of Services are Provided at a 11 Reasonable Cost

12 Q. Are the costs of the ES Environmental class of services reasonable?

13 A. Yes. The costs of the ES Environmental class of services are reasonable. The

14 management of the various air quality, water quality, and solid waste permits

15 requires background, expertise, and training in these areas. By having a central

16 organization managing these environmental areas, duplication of personnel and

17 resources at the various facilities subject to regulations is avoided.

18 1. Additional Evidence

19 Q. Is there any additional evidence that supports your opinion that the costs of

20 the ES Environmental affiliate class are reasonable?

21 A. Yes. Of the estimated Updated Test Year costs for the ES Environmental class,

22 approximately 93.96% are compensation and benefits costs for XES personnel.

23 Mr. Knoll and Mr. Schrubbe establish that the level of Xcel Energy's

24 compensation and benefits is reasonable and necessary.


RR 4 - Page 589 of 693 02398

1 2. Budget Planning

2 Q. Is a budget planning process applicable to the ES Environmental class of

3 affiliate costs?

4 A. Yes. Annual O&M budgets are created for the Environmental Services

5 organization, which includes the ES Environmental class of affiliate costs, using

6 guidelines developed at the corporate level. Each manager within the

7 Environmental Services organization carefully reviews historical spend

8 information, identifies changes that will be coming in the future, and analyzes the

9 costs associated with those changes prior to submitting a proposed budget. The

10 budgeting process is discussed in more detail by Mr. Dietenberger.

11 Q. During the fiscal year, does the Environmental Services organization monitor

12 its actual expenditures versus its budget?


14 management in the Environmental Services organization within each department.

15 Deviations are evaluated each month to ensure that costs are appropriate. In

16 addition, action plans are developed to mitigate variations in actual to budgeted

17 expenditures. These mitigation plans may either reduce or delay other

18 expenditures so that the revised budget supports the authorized budget. If

19 authorized budget adjustments are required, they are identified and approved at an

20 appropriate level of management.


RR 4 - Page 590 of 693 02399

Documents

Dff I E - Texas