docket no. 43695 application of southwestern …...2 a. i have an associate degree in applied...

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Bellinghausen Direct Revenue Requirement Page 1 DOCKET NO. 43695 APPLICATION OF SOUTHWESTERN PUBLIC SERVICE COMPANY FOR AUTHORITY TO CHANGE RATES § § § PUBLIC UTILITY COMMISSION OF TEXAS DIRECT TESTIMONY of ALAN L. BELLINGHAUSEN on behalf of SOUTHWESTERN PUBLIC SERVICE COMPANY (Filename: BellinghausenRRDirect.doc) Table of Contents GLOSSARY OF ACRONYMS AND DEFINED TERMS................................................ 2 LIST OF ATTACHMENTS ............................................................................................... 3 I. WITNESS IDENTIFICATION AND QUALIFICATIONS .................................. 4 II. ASSIGNMENT AND SUMMARY OF TESTIMONY AND RECOMMENDATIONS ........................................................................................ 7 III. AFFILIATE EXPENSES FOR THE TRANSMISSION & SUBSTATIONS CLASS OF SERVICES .............................................................. 9 A. SUMMARY OF AFFILIATE EXPENSES FOR THE TRANSMISSION & SUBSTATIONS CLASS OF SERVICES .............................................................. 9 B. THE TRANSMISSION & SUBSTATIONS CLASS OF SERVICES ARE NECESSARY SERVICES ............................................................................... 18 C. THE TRANSMISSION & SUBSTATIONS CLASS OF SERVICES ARE PROVIDED AT A REASONABLE COST .......................................................... 23 1. OBJECTIVE EVIDENCE (BENCHMARKING) ........................................... 23 2. BUDGET PLANNING ............................................................................. 24 3. COST TRENDS...................................................................................... 25 4. STAFFING TRENDS............................................................................... 26 5. COST CONTROL AND PROCESS IMPROVEMENT INITIATIVES ................ 27 D. THE COSTS FOR THE TRANSMISSION & SUBSTATIONS CLASS OF SERVICES ARE PRICED IN A FAIR MANNER................................................. 28 IV. CONCLUSION ..................................................................................................... 33 AFFIDAVIT ..................................................................................................................... 34 RR10 - Page 197 of 502 04565

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  • Bellinghausen Direct – Revenue Requirement Page 1

    DOCKET NO. 43695

    APPLICATION OF SOUTHWESTERN

    PUBLIC SERVICE COMPANY FOR

    AUTHORITY TO CHANGE RATES

    §

    §

    §

    PUBLIC UTILITY COMMISSION

    OF TEXAS

    DIRECT TESTIMONY

    of

    ALAN L. BELLINGHAUSEN

    on behalf of

    SOUTHWESTERN PUBLIC SERVICE COMPANY

    (Filename: BellinghausenRRDirect.doc)

    Table of Contents

    GLOSSARY OF ACRONYMS AND DEFINED TERMS................................................ 2

    LIST OF ATTACHMENTS ............................................................................................... 3

    I. WITNESS IDENTIFICATION AND QUALIFICATIONS .................................. 4

    II. ASSIGNMENT AND SUMMARY OF TESTIMONY AND

    RECOMMENDATIONS ........................................................................................ 7

    III. AFFILIATE EXPENSES FOR THE TRANSMISSION &

    SUBSTATIONS CLASS OF SERVICES .............................................................. 9

    A. SUMMARY OF AFFILIATE EXPENSES FOR THE TRANSMISSION &

    SUBSTATIONS CLASS OF SERVICES .............................................................. 9

    B. THE TRANSMISSION & SUBSTATIONS CLASS OF SERVICES ARE

    NECESSARY SERVICES ............................................................................... 18

    C. THE TRANSMISSION & SUBSTATIONS CLASS OF SERVICES ARE

    PROVIDED AT A REASONABLE COST .......................................................... 23

    1. OBJECTIVE EVIDENCE (BENCHMARKING) ........................................... 23

    2. BUDGET PLANNING ............................................................................. 24

    3. COST TRENDS ...................................................................................... 25

    4. STAFFING TRENDS ............................................................................... 26

    5. COST CONTROL AND PROCESS IMPROVEMENT INITIATIVES ................ 27

    D. THE COSTS FOR THE TRANSMISSION & SUBSTATIONS CLASS OF

    SERVICES ARE PRICED IN A FAIR MANNER ................................................. 28

    IV. CONCLUSION ..................................................................................................... 33

    AFFIDAVIT ..................................................................................................................... 34

    RR10 - Page 197 of 502 04565

  • Bellinghausen Direct – Revenue Requirement Page 2

    GLOSSARY OF ACRONYMS AND DEFINED TERMS

    Acronym/Defined Term

    Meaning

    Costs or costs

    O&M expenses and administrative and general

    expenses collectively

    FERC

    Federal Energy Regulatory Commission

    NERC North American Electric Reliability Corporation

    O&M

    operation and maintenance

    Operating Companies

    Northern States Power Company, a Minnesota

    corporation; Northern States Power Company, a

    Wisconsin corporation; PSCo; and SPS

    Operating Company One of the Operating Companies

    PSCo Public Service Company of Colorado, a Colorado

    corporation

    SAIDI System Average Interruption Duration Index

    SPP Southwest Power Pool

    SPS Southwestern Public Service Company, a New

    Mexico corporation

    Test Year July 1, 2013 through June 30, 2014

    Total Company or total

    company

    Total SPS (before any jurisdictional allocation)

    TRO Transmission Resource Optimization

    Xcel Energy Xcel Energy Inc.

    XES Xcel Energy Services Inc.

    RR10 - Page 198 of 502 04566

  • Bellinghausen Direct – Revenue Requirement Page 3

    LIST OF ATTACHMENTS

    Attachment

    Description

    ALB-RR-1

    Organization Chart - Transmission

    (Non-native format)

    ALB-RR-A Summary of XES Expenses to SPS by Affiliate

    Class and Billing Method

    (Filename: ALB-RR-A.xls)

    ALB-RR-B XES Expenses to all Affiliates by Affiliate Class,

    Activity, Billing Method and FERC Account

    (Filename: ALB-RR-B.xls)

    ALB-RR-C Exclusions from XES Expenses to SPS by Affiliate

    Class and FERC Account

    (Filename: ALB-RR-C.xls)

    ALB-RR-D Pro Forma Adjustments to XES Expenses by

    Affiliate Class and FERC Account

    (Filename: ALB-RR-D.xls)

    RR10 - Page 199 of 502 04567

  • Bellinghausen Direct – Revenue Requirement Page 4

    DIRECT TESTIMONY

    OF

    ALAN L. BELLINGHAUSEN

    I. WITNESS IDENTIFICATION AND QUALIFICATIONS 1

    Q. Please state your name and business address. 2

    A. My name is Alan L. Bellinghausen. My business address is 600 South Tyler 3

    Street, Amarillo, Texas 79101. 4

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

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

    (“SPS”), a New Mexico corporation and wholly-owned electric utility subsidiary 7

    of Xcel Energy Inc. (“Xcel Energy”). Xcel Energy is a registered holding 8

    company that owns several electric and natural gas utility operating companies.1 9

    Q. By whom are you employed and in what position? 10

    A. I am employed by SPS, as Regional Director, Substation Operations and 11

    Maintenance. 12

    Q. Please briefly outline your responsibilities as Regional Director, Substation 13

    Operations and Maintenance. 14

    A. I am responsible for the operation and maintenance (“O&M”) of SPS’s 15

    transmission and distribution substations in Texas and New Mexico, and 16

    transmission-only facilities in Oklahoma and Kansas. 17

    1 Xcel Energy is the parent company of four wholly-owned electric utility operating companies:

    Northern States Power Company, a Minnesota corporation; Northern States Power Company, a Wisconsin

    corporation; Public Service Company of Colorado, a Colorado corporation (“PSCo”); and SPS

    (collectively, “Operating Companies”; individually, “Operating Company”). Xcel Energy’s natural gas

    pipeline subsidiary is WestGas InterState, Inc. Xcel Energy also has two transmission-only operating

    companies, Xcel Energy Southwest Transmission Company, LLC and Xcel Energy Transmission

    Development Company, LLC, which are regulated by the Federal Energy Regulatory Commission

    (“FERC”).

    RR10 - Page 200 of 502 04568

  • Bellinghausen Direct – Revenue Requirement Page 5

    Q. Please describe your educational background. 1

    A. I have an Associate Degree in Applied Science Management Development from 2

    Amarillo College in Amarillo, Texas. 3

    Q. Please describe your professional experience. 4

    A. I have worked in the electric utility industry since 1975. All of my experience has 5

    been with Xcel Energy and its predecessor companies. From 1975 to 1992, I 6

    worked in the Substation Construction Department, starting as an apprentice 7

    electrician and becoming substation general foreman in 1986. From 1993 to 8

    1996, I was employed as the division supervisor for the Panhandle Substation 9

    Operations and Maintenance department. In 1996, I worked on a one-year 10

    assignment in support of the SPS and PSCo merger, following which I worked as 11

    the manager for the Texas North Substation Operations and Maintenance 12

    department through 2006. In 2007, I became interim manager for SPS Substation 13

    Construction, Operations and Maintenance, and in 2008, I became the Regional 14

    Director, Substation Construction Operations and Maintenance for the SPS 15

    region. As of 2012, my title was changed to Regional Director, Substation 16

    Operations and Maintenance, and my responsibilities for Substation Construction 17

    were shifted to the Transmission Field Operations organization. 18

    Q. Are you a member of any professional organizations? 19

    A. Yes. I am a Senior Member of the Institute of Electrical and Electronics 20

    Engineers. 21

    RR10 - Page 201 of 502 04569

  • Bellinghausen Direct – Revenue Requirement Page 6

    Q. Have you filed testimony before any regulatory authorities? 1

    A. Yes. I filed testimony at the Public Utility Commission of Texas in Docket Nos. 2

    40824 and 42004 on the Transmission & Substations class of affiliate costs and in 3

    Docket No. 38147 on the Transmission & Substations and the Safety classes of 4

    affiliate costs. 5

    RR10 - Page 202 of 502 04570

  • Bellinghausen Direct – Revenue Requirement Page 7

    II. ASSIGNMENT AND SUMMARY OF TESTIMONY AND 1 RECOMMENDATIONS 2

    Q. What is your assignment in this proceeding? 3

    A. I support the Test Year (July 1, 2013 through June 30, 2014, “Test Year”) O&M 4

    expenses and the administrative and general expenses (collectively, “costs” or 5

    “Costs”) for the Transmission & Substations class of affiliate services. In regard 6

    to this affiliate class, my testimony will: 7

    describe the services included in the class; 8

    explain that those services are reasonable and necessary for SPS’s 9 operation; 10

    explain that the costs for those services are reasonable and necessary; 11

    explain that these services do not duplicate services that SPS provides 12 to itself through its own employees or that are provided from any other 13

    source; and 14

    explain that charges from Xcel Energy Services Inc. (“XES”), the 15 service company subsidiary of Xcel Energy, to SPS for those services 16

    are no higher than the charges to SPS affiliates for the same or similar 17

    services. 18

    Q. Please summarize the recommendations and conclusions in your testimony. 19

    A. The Test Year costs that SPS seeks to recover for the services of the Transmission 20

    & Substations affiliate class of $5,257,125 (total SPS before jurisdictional 21

    allocations, “total company” or “Total Company”) are reasonable and necessary 22

    because they support SPS’s ability to provide electric service to its Texas retail 23

    customers. 24

    The costs are for services provided by XES that are necessary to the 25 planning, siting, design, construction, operation, and maintenance of 26

    SPS’s transmission assets. 27

    RR10 - Page 203 of 502 04571

  • Bellinghausen Direct – Revenue Requirement Page 8

    The costs are reasonable because they are shared with other affiliates, 1 consist primarily of reasonable personnel costs, and are subjected to 2

    rigorous budgeting and cost control processes. 3

    SPS does not provide these services for itself, and the services do not 4 duplicate services provided by others. 5

    The charge from SPS’s affiliate for these services is no higher than the 6 charge by that affiliate to any other entity for the same or similar 7

    service, and the costs reasonably approximate the affiliate’s cost to 8

    provide the service. 9

    RR10 - Page 204 of 502 04572

  • Bellinghausen Direct – Revenue Requirement Page 9

    III. AFFILIATE EXPENSES FOR THE TRANSMISSION & 1 SUBSTATIONS CLASS OF SERVICES 2

    Q. Earlier in your testimony, you referred to an “affiliate class.” What do you 3

    mean by the terms “affiliate class” or “affiliate class of services”? 4

    A. A portion of SPS’s costs reflect 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, SPS witness Janet S. Schmidt-Petree provides a detailed explanation of 10

    how the affiliate classes were developed and are organized for this case. 11

    Q. Which affiliate class do you sponsor? 12

    A. I sponsor the Transmission & Substations class of affiliate services. 13

    A. Summary of Affiliate Expenses for the Transmission & 14

    Substations Class of Services 15

    Q. Where does the Transmission & Substations affiliate class fit into the overall 16

    affiliate structure? 17

    A. Attachment JSSP-RR-6 to Ms. Schmidt-Petree’s direct testimony provides a list 18

    and a pictorial display of all affiliate classes, dollar amounts for those classes, and 19

    sponsoring witness for each class. As seen on that attachment, the Transmission 20

    & Substations affiliate class was part of the Transmission business area during the 21

    Test Year. Attachment ALB-RR-1 to my testimony is an organization chart 22

    showing the Transmission organization. 23

    RR10 - Page 205 of 502 04573

  • Bellinghausen Direct – Revenue Requirement Page 10

    Q. What services are grouped into the Transmission & Substations affiliate 1

    class? 2

    A. The services that are grouped into the Transmission & Substations affiliate class 3

    are the oversight of the planning, siting, design, construction, operation, and 4

    maintenance of transmission assets. 5

    Q. What is the dollar amount of the Test Year XES charges that SPS requests, 6

    on a total company basis, for the Transmission & Substations affiliate class? 7

    A. The following table summarizes the dollar amount of the Test Year XES charges 8

    for the Transmission & Substations affiliate class. The table headings are 9

    explained following the table. 10

    Table ALB-RR-1 11

    Requested Amount of XES Class Expenses

    Billed to SPS (Total Company)

    Class of

    Services

    Total XES

    Class

    Expenses

    Requested

    Amount

    % Direct

    Billed % Allocated

    Transmission

    & Substations $28,116,097 $5,257,125 67% 33%

    12

    Total XES Class Expenses

    Dollar amount of total 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 F in Attachment

    ALB-RR-A, which I will discuss in the next

    question.

    Requested Amount of XES

    Class Expenses Billed to SPS

    (Total Company)

    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 L in Attachment

    ALB-RR-A.

    RR10 - Page 206 of 502 04574

  • Bellinghausen Direct – Revenue Requirement Page 11

    % Direct Billed The percentage of SPS’s requested XES

    expenses (total company) for this class that were

    billed 100% to SPS.

    % Allocated The percentage of SPS’s requested XES

    expenses (total company) for this class that were

    allocated to SPS.

    Q. Please describe the attachments that support the information provided in 1

    Table ALB-RR-1. 2

    A. There are four attachments to my testimony that present information about the 3

    requested SPS affiliate expenses for the Transmission & Substations affiliate 4

    class. 5

    Attachment ALB-RR-A: Provides a summary of the affiliate expenses 6

    for this class. The summary starts with the total of the XES expenses to all Xcel 7

    Energy affiliates for the services provided by this affiliate class and ends with the 8

    requested dollar amount of XES expenses to SPS (total company) for this affiliate 9

    class after exclusions and pro forma adjustments. The columns on this attachment 10

    provide the following information. 11

    Column A — Line number Lists the Attachment line numbers.

    Column B —

    Business Area

    Provides the business area associated

    with the affiliate class.

    Column C —

    Affiliate Class

    Lists the affiliate class.

    RR10 - Page 207 of 502 04575

  • Bellinghausen Direct – Revenue Requirement Page 12

    Column D —

    Billing Method

    (Work Order)

    Shows the billing method code that

    XES uses to charge the expenses to the

    affiliates, and the billing method short

    title. In her direct testimony, Ms.

    Schmidt-Petree explains the billing

    methods and defines the codes.

    Column E —

    Allocation Method

    Shows the allocation method applicable

    to the billing method (work order).

    Column F —

    Total XES Billings

    for Class to all Legal

    Entities (FERC Acct.

    400-935)

    Shows the total XES billings to all

    affiliates (i.e., Xcel Energy legal

    entities), including SPS, for FERC

    Accounts 400 through 935 for the

    affiliate class.

    Column G —

    XES Billings for

    Class to all Legal

    Entities Except for

    SPS (FERC Acct.

    400-935)

    Shows XES billings to all affiliates,

    other than to SPS, for FERC Accounts

    400 through 935 for the affiliate class.

    Column H —

    XES Billings for

    Class to SPS (total

    company) (FERC

    Acct. 400-935)

    Shows XES billings to SPS (total

    company) for the affiliate class. The

    sum of the dollar amounts in Columns

    G and H equal the dollar amount in

    Column F.

    Column I —

    Exclusions

    Shows the total dollars to be excluded

    from Column H. Exclusions reflect

    expenses not requested, such as

    expenses not allowed or other below-

    the-line items.

    Column J —

    Per Book

    Shows XES billings to SPS (total

    company), for the affiliate class, after

    the exclusions shown in Column I. The

    dollar amount in Column J is Column

    H plus Column I.

    RR10 - Page 208 of 502 04576

  • Bellinghausen Direct – Revenue Requirement Page 13

    Column K —

    Pro Formas

    Shows the total dollar amount of pro

    forma adjustments to the dollar amount

    in Column J. Pro forma adjustments

    reflect revisions for known and

    measurable changes to Test Year

    expenses.

    Column L —

    Requested Amount

    (total company)

    Shows the requested amount (total

    company) for the affiliate class. The

    dollar amount in Column L is Column J

    plus Column K.

    Column M —

    Percentage of class

    charges

    Shows the percentage of affiliate class

    charges billed using the work order.

    In her direct testimony, Ms. Schmidt-Petree describes in detail the 1

    calculations that take the dollars of Total XES Billings in Column F to the 2

    Requested Amount in Column L. 3

    Attachment ALB-RR-B: Provides the detail of the XES expenses for the 4

    Transmission & Substations affiliate class that are summarized on Attachment 5

    ALB-RR-A. The detail shows the XES expenses for the Transmission & 6

    Substations affiliate class, itemized by the amount going to each legal entity 7

    receiving the expense (Xcel Energy or one of its subsidiaries), and with each 8

    expense listed by individual work order, activity, and billing method. When 9

    summed, these amounts tie to the amounts shown on Attachment ALB-RR-A and 10

    the detail regarding the expenses is organized to support that attachment. 11

    Specifically, the columns on this attachment provide the following information. 12

    RR10 - Page 209 of 502 04577

  • Bellinghausen Direct – Revenue Requirement Page 14

    1

    Column A — Line Number Lists the Attachment line numbers.

    Column B —

    Legal Entity

    Receiving XES

    Expense

    Shows the legal entity (Xcel Energy or

    one of its subsidiaries) that received the

    XES expense.

    Column C —

    Affiliate Class

    Lists the affiliate class.

    Column D —

    Activity

    The short title for the activity.

    Column E —

    Billing Method

    (Work Order)

    The billing method code and short title.

    In her direct testimony, Ms. Schmidt-

    Petree explains the billing methods and

    defines the codes.

    Column F —

    FERC Account

    Shows the FERC Account in which the

    expense was recorded.

    Column G —

    Total XES Billings

    for Class to all Legal

    Entities (FERC Acct.

    400-935)

    Shows the itemized amount of the

    listed XES expense that was billed to

    the listed legal entity. The itemized

    amounts are then summed to show the

    total XES billings to all affiliates (i.e.,

    Xcel Energy legal entities) by work

    order and FERC Account for the

    affiliate class. The total dollar amount

    for the affiliate class in Column G ties

    to the total dollar amount for the

    affiliate class in Column F of

    Attachment ALB-RR-A.

    RR10 - Page 210 of 502 04578

  • Bellinghausen Direct – Revenue Requirement Page 15

    Column H —

    XES Billings for

    Class to all Legal

    Entities Except for

    SPS (FERC Acct.

    400-935)

    Shows the same information as

    provided in Column G, except that

    billings to SPS are excluded from this

    column. Therefore, the sum of this

    column provides total billings to all

    legal entities other than SPS and ties to

    the total dollar amount for the affiliate

    class in Column G of Attachment

    ALB-RR-A.

    Column I —

    XES Billings for

    Class to SPS (Total

    Company) (FERC

    Acct. 400-935)

    Shows the same information as

    provided in Column G, except that only

    billings to SPS are included. (The

    dollar amounts in Columns H and I

    equal the dollar amount in Column G.)

    Therefore, the sum of this column

    provides total billings to SPS and ties to

    the total dollar amount for the affiliate

    class in Column H of Attachment

    ALB-RR-A.

    Attachment ALB-RR-C: Both Attachments ALB-RR-A and ALB-RR-B 1

    show exclusions to the XES expenses billed to SPS for the Transmission & 2

    Substations affiliate class (Attachment ALB-RR-A, Column I; Attachment 3

    ALB-RR-B, Column J). Attachment ALB-RR-C provides detail about those 4

    exclusions listed on Attachments ALB-RR-A and ALB-RR-B. The columns on 5

    this Attachment ALB-RR-C provide the following information. 6

    Column A — Line Number Lists the Attachment line numbers.

    Column B —

    Affiliate Class

    Lists the affiliate class.

    Column C —

    FERC Account

    The FERC Account for the expense

    that has been excluded.

    RR10 - Page 211 of 502 04579

  • Bellinghausen Direct – Revenue Requirement Page 16

    Column D —

    Explanations for

    Exclusions

    Brief rationale for the exclusion.

    Column E —

    Exclusions (total

    company)

    Dollar amount of the exclusion.

    In her direct testimony, Ms. Schmidt-Petree describes the calculations 1

    underlying the exclusions. 2

    Attachment ALB-RR-D: Both Attachments ALB-RR-A and ALB-RR-B 3

    show pro forma adjustments to SPS’s per book expenses for the Transmission & 4

    Substations affiliate class (Attachment ALB-RR-A, Column K; Attachment 5

    ALB-RR-B, Column L). Attachment ALB-RR-D provides information about 6

    those pro forma adjustments shown on Attachments ALB-RR-A and ALB-RR-B. 7

    The columns on this attachment provide the following information. 8

    Column A — Line Number Lists the Attachment line numbers.

    Column B —

    Affiliate Class

    Lists the affiliate class.

    Column C —

    FERC Account

    The FERC Account affected by the pro

    forma adjustment.

    Column D —

    Explanations for Pro

    Formas

    Brief rationale for the pro forma

    adjustment.

    Column E —

    Sponsor

    The witness or witnesses who sponsor

    the pro forma adjustment.

    Column F —

    Pro Formas (total

    company)

    Dollar amount of the pro forma

    adjustment.

    RR10 - Page 212 of 502 04580

  • Bellinghausen Direct – Revenue Requirement Page 17

    Q. Does XES bill all of its expenses for the Transmission & Substations affiliate 1

    class to SPS? 2

    A. No. XES bills the majority of its expenses for the Transmission & Substations 3

    affiliate class to affiliates other than SPS. SPS receives approximately 19% of 4

    total XES billings for the Transmission & Substations class, as shown on 5

    Attachment ALB-RR-A (Columns F, G, and H) and Attachment ALB-RR-B 6

    (Columns G, H, and I). 7

    Q. Are there any exclusions to the XES billings to SPS for the Transmission & 8

    Substations affiliate class? 9

    A. Yes. As I mentioned earlier, exclusions reflect expenses not requested, such as 10

    expenses not allowed or other below-the-line items. Exclusions are shown on 11

    Attachment ALB-RR-A, Column I, and on Attachment ALB-RR-B, Column J. 12

    The details for the exclusions are provided in Attachment ALB-RR-C. As I also 13

    mentioned earlier, Ms. Schmidt-Petree describes how the exclusions were 14

    calculated. 15

    Q. Are there any pro forma adjustments to SPS’s per book expenses for the 16

    Transmission & Substations affiliate class? 17

    A. Yes. As I mentioned earlier, pro forma adjustments are revisions to Test Year 18

    expenses for known and measurable changes. Pro forma adjustments are shown 19

    on Attachment ALB-RR-A, Column K, and on Attachment ALB-RR-B, 20

    Column L. The details for the pro forma adjustments, including the witness or 21

    witnesses who sponsor each pro forma adjustment, are provided in Attachment 22

    ALB-RR-D. 23

    RR10 - Page 213 of 502 04581

  • Bellinghausen Direct – Revenue Requirement Page 18

    Q. Attachment ALB-RR-D shows that you are a sponsor for pro forma 1

    adjustments that result in a decrease for the Transmission & Substations 2

    affiliate class of $2,761. Please explain the adjustments. 3

    A. The adjustments that I sponsor remove charges for alcoholic beverages (a 4

    decrease of $2,564) and adjust a number of other small charges. 5

    B. The Transmission & Substations Class of Services are Necessary 6

    Services 7

    Q. Are the services that are grouped in the Transmission & Substations affiliate 8

    class necessary for SPS’s operations? 9

    A. Yes. The services grouped in the Transmission & Substations affiliate class are 10

    necessary to ensure that the transmission system, which is essential to bringing 11

    safe and reliable electric service to SPS’s customers, is appropriately operated and 12

    maintained. They are functions required by all utilities and without which SPS 13

    would not be able to provide electric service to its customers. 14

    Q. What are the specific services that are provided to SPS by the Transmission 15

    & Substations affiliate class? 16

    A. The specific services that are provided to SPS by the Transmission & Substations 17

    affiliate class are: 18

    Managing and directing the O&M of transmission lines and 19 substations located in the Texas Panhandle, eastern and southeastern 20

    New Mexico, the Oklahoma Panhandle, and southwestern Kansas. 21

    The transmission system has transmission lines and substations that 22

    operate at 345, 230, 115, and 69 kilovolts. 23

    Managing and directing the Operations Center in Amarillo, Texas, 24 which provides round-the-clock operation of the SPS transmission 25

    system. The Operations Center monitors load and generation balance, 26

    monitors and controls the transmission system, dispatches switching 27

    for equipment maintenance, dispatches outage restoration efforts, 28

    maintains and drills emergency operations plans, coordinates 29

    RR10 - Page 214 of 502 04582

  • Bellinghausen Direct – Revenue Requirement Page 19

    operations with electrically adjacent utilities, and participates in 1

    regional reliability activities. 2

    Providing engineering and design services, system protection services, 3 right of way procurement, maintenance and operations engineering, 4

    and project management services for capital project development. 5

    Managing transmission system planning, interconnection contracts, 6 and physical projects necessary to interconnect new generation and 7

    new end-use customers to the grid. 8

    Coordinating with the Southwest Power Pool (“SPP”) on operations, 9 scheduling, and system development; monitoring the activities of the 10

    SPP with regard to the impact on the SPS transmission system, 11

    providing input to SPP planning, and developing and executing 12

    strategic initiatives. 13

    Providing oversight of compliance tracking with respect to the North 14 American Electric Reliability Corporation (“NERC”) and Electric 15

    Reliability Organization standards; managing the Transmission O&M 16

    budget; and providing oversight of the Transmission Resource 17

    Optimization (“TRO”) initiative. 18

    Tracking performance, providing technical training, establishing 19 maintenance criteria, and establishing standards for the transmission 20

    system (including both lines and substations), the electric distribution 21

    system (including both lines and substations), and the metering 22

    functions of the transmission and distribution electrical system. 23

    Managing the corporate-wide transmission organization. 24

    Q. Are any of the Transmission & Substations class of services that are provided 25

    to SPS duplicated elsewhere in XES or in any other Xcel Energy subsidiary 26

    such as SPS itself? 27

    A. No. Within XES, none of the services grouped in the Transmission & Substations 28

    affiliate class are duplicated elsewhere. No other Xcel Energy subsidiary 29

    performs these services for the Operating Companies. In addition, SPS does not 30

    perform these services for itself. Although there are both XES and SPS 31

    employees in the Transmission organization, the SPS employees do not perform 32

    the same activities as the XES employees and they have separate responsibilities 33

    and roles. I described earlier the activities of the XES employees. There are also 34

    RR10 - Page 215 of 502 04583

  • Bellinghausen Direct – Revenue Requirement Page 20

    approximately 315 SPS employees who perform transmission functions. These 1

    include system operators, dispatchers, transmission system planners, engineers, 2

    designers, engineering technicians, journeymen linemen, journeyman electricians, 3

    relay technicians, heavy equipment operators, mechanics, truck drivers, 4

    apprentices, working foremen, office support, and in most instances their 5

    respective supervisors. The services provided by these SPS employees are not 6

    duplicative of services provided by XES employees, although they work in 7

    coordination with and under the direction of the XES Transmission business area 8

    management. 9

    Q. Do SPS’s Texas retail customers benefit from the services that are part of the 10

    Transmission & Substations class of services? 11

    A. Yes. The services of the Transmission & Substations affiliate class benefit SPS’s 12

    customers by supporting the safe and reliable transmission of energy resources 13

    from the generators to the distribution system. For example, the Transmission 14

    Line Performance department monitors reliability performance and develops 15

    reliability improvement plans for the transmission lines that are used to transport 16

    electricity to SPS’s customers. The reliability improvement plan that the 17

    department developed for 2010 through 2013 included initiatives for: 18

    replacement of poles, cross arms, and switches that were nearing their end of life; 19

    reinforcement of poles on transmission lines where replacement was not yet 20

    necessary; and enhancement of vegetation management for transmission. The 21

    plan developed by the department for 2013 through 2018, includes reliability 22

    improvement initiatives that are focused on: patrol-based end of life replacements 23

    RR10 - Page 216 of 502 04584

  • Bellinghausen Direct – Revenue Requirement Page 21

    on transmission structures and transmission switches; individual circuit renewal 1

    and refurbishment on the worst performing circuits; and adding or upgrading 2

    transmission lines and developing mitigation plans to improve reliability on high 3

    usage lines. 4

    Similarly, the Substation System Performance department monitors 5

    reliability performance and develops reliability improvement plans for the 6

    transmission and distribution substations that are necessary for providing 7

    electricity to SPS’s customers. The plan for 2013 through 2018 includes 8

    reliability improvement initiatives focused on: infrastructure renewal with the 9

    replacement of equipment that is at or near end of life; prioritized maintenance of 10

    transmission and distribution circuit breakers, transmission and distribution 11

    transformers, distribution voltage regulators, and transmission instrument 12

    transformers that are deemed to present the highest risk to the system; installation 13

    of substation animal deterrent systems; upgrades of substation perimeter fences; 14

    installation of protective schemes to allow reclosing after bus faults caused by 15

    animals; and installation of additional Remote Terminal Units at distribution 16

    substations. Ongoing maintenance activities include the performance of condition 17

    assessments on relay protection schemes and batteries, and diagnostics on circuit 18

    breakers, transformers, and regulators. 19

    Q. What are the trends with regard to the reliability statistics for the SPS 20

    transmission system? 21

    A. The primary reliability metric tracked is the System Average Interruption 22

    Duration Index (“SAIDI”), which is defined as the average number of minutes 23

    RR10 - Page 217 of 502 04585

  • Bellinghausen Direct – Revenue Requirement Page 22

    that a customer is interrupted in a given time period due to an outage. SAIDI is 1

    tracked at several levels, including distribution line, distribution substation, 2

    transmission line, and transmission substation. Table ALB-RR-2 reflects the 3

    SAIDI for the previous five years for transmission lines and all substations. 4

    Table ALB-RR-2 5

    Year Transmission

    Line

    SAIDI

    Transmission

    Substation

    SAIDI

    Distribution

    Substation

    SAIDI

    Total Transmission

    & Substation

    SAIDI

    2013 13.48 3.49 3.48 20.45

    2012 7.22 1.50 9.25 17.97

    2011 11.41 1.60 15.24 28.25

    2010 1.06 0.98 9.13 11.17

    2009 10.55 0.19 10.10 20.84

    The 2013 SAIDI for transmission lines and substations totaled 20.45 6

    minutes which was an increase of 2.48 minutes over the 2012 level. The increase 7

    was due to a single outage in Carlsbad, New Mexico that was caused by an oil 8

    field truck that ran off the road and significantly damaged a transmission line 9

    structure with multiple transmission line circuits. The outage was lengthy 10

    because the local law enforcement agency considered the location a crime scene 11

    and would not allow SPS crews access to the structure to make repairs for several 12

    hours.2 This single event impacted the 2013 SAIDI by 2.92 minutes. Had this 13

    event not taken place, the 2013 SAIDI would have been 17.53 which would have 14

    been an improvement of 0.44 minutes over the 2012 total of 17.97 minutes. The 15

    higher total of 28.25 minutes in 2011 was attributed primarily to two outages on 16

    2 The accident occurred when the driver of the truck was stabbed by his estranged wife who was a

    passenger.

    RR10 - Page 218 of 502 04586

  • Bellinghausen Direct – Revenue Requirement Page 23

    radial transmission lines, one caused by a grassfire and the other by a structure 1

    that failed during a thunderstorm, and an increased number of outages due to 2

    circuit breaker failures that increased the distribution substation SAIDI, 3

    conditions which were not repeated in 2012. Weather conditions in 2010 were 4

    very mild, and the resulting transmission line SAIDI for that year reflects that 5

    phenomenon. Comparisons to 2009 results are therefore more meaningful for 6

    trending purposes. 7

    C. The Transmission & Substations Class of Services are Provided at 8

    a Reasonable Cost 9

    Q. Are the costs of the Transmission & Substations class of services reasonable? 10

    A. Yes. The costs of the Transmission & Substations class of services are 11

    reasonable. XES provides these services on a consolidated basis, which provides 12

    SPS with the benefit of a pool of talented professionals, economies of scale, and 13

    the distribution of the consolidated costs among the Operating Companies. By 14

    managing these functions through XES, resources are used as efficiently as 15

    possible across the Operating Companies’ transmission organization, resulting in 16

    lower costs overall. 17

    1. Objective Evidence (Benchmarking) 18

    Q. Is there any objective evidence that supports your opinion that the costs of 19

    the Transmission & Substations affiliate class are reasonable? 20

    A. Yes. SPS witness Richard D. Starkweather presents a comparison of SPS’s 21

    transmission O&M expenses with other utilities’ transmission O&M expenses, as 22

    reported on the FERC Form 1. The costs of the Transmission & Substations class 23

    are reflected within those transmission O&M expenses. In addition, of the 24

    RR10 - Page 219 of 502 04587

  • Bellinghausen Direct – Revenue Requirement Page 24

    requested costs for the Transmission & Substations class, 75.50% are 1

    compensation and benefits costs for XES personnel. SPS witness Jill H. Reed 2

    establishes that the level of Xcel Energy’s compensation and benefits is 3

    reasonable and necessary. 4

    2. Budget Planning 5

    Q. Is a budget planning process applicable to the Transmission & Substations 6

    class of affiliate costs? 7

    A. Yes. Annual O&M budgets are created for the Transmission business area, which 8

    includes the Transmission & Substations class of affiliate costs, using guidelines 9

    developed at the corporate level. Each manager within the Transmission 10

    organization carefully reviews historical spend information, identifies changes 11

    that will be coming in the future, and analyzes the costs associated with those 12

    changes prior to submitting a proposed budget. The budgeting process is 13

    discussed in more detail by SPS witness Raynard A. Gray. 14

    Q. During the fiscal year, does the Transmission business area monitor its actual 15

    expenditures versus its budget? 16

    A. Yes. Actual versus expected expenditures are monitored on a monthly basis by 17

    management within each department of the Transmission organization. 18

    Deviations are evaluated each month to ensure that costs are appropriate. In 19

    addition, action plans are developed to mitigate variations in actual to budgeted 20

    expenditures. These mitigation plans may either reduce or delay other 21

    expenditures so that overall spending complies with the authorized budget. 22

    RR10 - Page 220 of 502 04588

  • Bellinghausen Direct – Revenue Requirement Page 25

    Q. Are employees within the Transmission business area held accountable for 1

    deviations from the budget? 2

    A. Yes. All management employees in the Transmission business area have specific 3

    budgetary targets that are measured on a monthly basis to ensure adherence to the 4

    targets and provide for action plan development to address variances. All XES 5

    Transmission management employees are required to manage their expenses to 6

    support the budgetary goals established by their manager. 7

    3. Cost Trends 8

    Q. Please state the dollar amounts of the actual charges (per book) from XES to 9

    SPS for the Transmission & Substations class of services for the three fiscal 10

    years preceding the end of the Test Year and the Test Year. 11

    A. The following table shows, for the fiscal years 2011, 2012, and 2013 (calendar 12

    years) and for the Test Year, the actual per book affiliate charges (Column J on 13

    Attachment ALB-RR-A) from XES to SPS for the services grouped in the 14

    Transmission & Substations affiliate class: 15

    Table ALB-RR-3 16

    Actual (Per Book) Charges Over Time

    Class of

    Services 2011 2012 2013 Test Year

    Transmission

    & Substations $3,136,849 $3,959,570 $4,996,222 $5,318,567

    Q. What are the reasons for this trend? 17

    A. The increase in costs from 2011 to 2012 was primarily related to increases in 18

    staffing as a result of the seven new departments created in 2010 and additional 19

    RR10 - Page 221 of 502 04589

  • Bellinghausen Direct – Revenue Requirement Page 26

    staffing in the Transmission Training group. The increase in costs between 2012 1

    and 2013 was the result of additional labor costs and employee expenses related 2

    to employees transferred from other Operating Companies to XES, and new 3

    employees primarily in the engineering, project management, and project control 4

    departments that were necessary to meet the demands of the aggressive capital 5

    build out of the SPS transmission system. The increase in costs between 2013 6

    and the Test Year was due to the additional labor and employee expenses related 7

    to the increased headcount in the engineering and project management 8

    departments to support the capital build out, as well as consulting fees for 9

    validation of facility ratings of the transmission system and system performance 10

    following the loss of a single bulk electric system element to be compliant with 11

    NERC and FERC requirements.3 12

    4. Staffing Trends 13

    Q. Please provide the staffing levels for the Transmission & Substations class of 14

    services for the three fiscal years preceding the end of the Test Year and the 15

    Test Year. 16

    A. The following table shows, for the fiscal years 2011, 2012, and 2013 (calendar 17

    years) and for the Test Year, the average of the end of month staffing levels for 18

    the Transmission & Substations class of services. 19

    3 Reliability Standard FAC-008-3 (Facility Ratings), adopted under 137 FERC ¶ 61,123, Docket No.

    RD11-10-000 (Nov. 17, 2011) available at http://www.nerc.net/standardsreports/standardssummary.aspx#; FERC

    Order 754 (Interpretation of Transmission Planning Reliability Standard), adopted under 136 FERC ¶ 61,186, Docket

    No. RM10-6-000 (September 15, 2011), available at http://www.ferc.gov/whats-new/comm-meet/2011/091511/E-

    4.pdf.

    RR10 - Page 222 of 502 04590

  • Bellinghausen Direct – Revenue Requirement Page 27

    Table ALB-RR-4 1

    Average End of Month # of Staff

    Class of Services 2011 2012 2013 Test Year

    Transmission &

    Substations 166 206 265 274

    Q. What are the reasons for this trend? 2

    A. The increases in average staffing levels between 2011 and 2012 were the result of 3

    the establishment and staffing of new departments and staff additions in the 4

    Transmission Training group in 2012. There were also increases in staffing of 5

    several departments created in 2011 and 2012 to bring them up to appropriate 6

    staffing levels. The increase in average staffing levels between 2012 and 2013 7

    was primarily related to adding staff to support the capital build out in the SPS 8

    territory by transferring employees and their management from other Operating 9

    Companies to XES and adding employees in the engineering, project 10

    management, and project controls departments. The increase in average staffing 11

    levels between 2013 and the Test Year was the result of adding employees in the 12

    engineering and project management departments to support the capital build out. 13

    5. Cost Control and Process Improvement Initiatives 14

    Q. Separate from the budget planning process, does the Transmission & 15

    Substations affiliate class take any steps to control its costs or to improve its 16

    services? 17

    A. Yes. The Transmission organization has several initiatives that are focused on 18

    driving productivity and effectiveness. For example, the TRO initiative, a 19

    long-term process improvement program, encompasses maintenance activities as 20

    RR10 - Page 223 of 502 04591

  • Bellinghausen Direct – Revenue Requirement Page 28

    well as capital projects. It establishes an organizational framework, management 1

    philosophy, and a focus on improving processes and more clearly defining roles 2

    and responsibilities. These efforts assist in controlling costs and improving 3

    services. 4

    D. The Costs for the Transmission & Substations Class of Services 5

    are Priced in a Fair Manner 6

    Q. For those costs that XES charges (either directly or through use of an 7

    allocation) to SPS for the Transmission & Substations class of services, does 8

    SPS pay any more for the same or similar service than does any other Xcel 9

    Energy affiliate? 10

    A. No. 11

    Q. Why do you answer “no”? 12

    A. The XES charges to SPS for any particular service are no higher than the XES 13

    charges to any other Xcel Energy affiliate. The costs charged for particular 14

    services are the actual costs that XES incurred in providing those services to SPS. 15

    A single, specific billing method, rationally related to the costs drivers associated 16

    with the service being provided, is used with each work order. In her direct 17

    testimony, Ms. Schmidt-Petree discusses the selection of billing methods and 18

    XES’s method of charging for services in more detail. 19

    Q. How are the costs of the Transmission & Substations affiliate class billed to 20

    SPS? 21

    A. My Attachment ALB-RR-B shows all of the costs in this class broken out by 22

    activity and shows the billing method associated with each activity. 23

    RR10 - Page 224 of 502 04592

  • Bellinghausen Direct – Revenue Requirement Page 29

    Q. What are the predominant billing methods used for the costs that SPS seeks 1

    to recover for the Transmission & Substations affiliate class of services? 2

    A. Of the requested XES charges to SPS for this class, 98.55% were charged using 3

    one of the following two methods: 4

    Direct Billing – 67.34% of XES charges to SPS - $3,539,960.89; and 5

    Electric Transmission Plant – 31.21% of XES charges to SPS - 6 $1,640,914.85 7

    Q. Why is the “Direct Billing” method appropriate for assigning the costs 8

    captured in the work orders that use that billing method? 9

    A. For the work orders that are assigned using the “Direct Billing” method, the costs 10

    normally reflect work that was performed specifically for SPS only. In some 11

    cases, however, the direct billing occurred after the application of an off-line 12

    allocator that tracks the relevant cost drivers. In either situation, the work orders 13

    charged using the “Direct Billing” method are appropriate because the assignment 14

    of costs is in accordance with the distribution of benefits for the services received. 15

    For example, the labor and employee expense costs associated with regional 16

    planning activities for SPS’s transmission system were assigned using the “Direct 17

    Billing” method. The cost of these services benefitted SPS, the work was 18

    performed specifically for SPS alone, and the cost drivers were the regional 19

    planning activities and associated load studies required for SPS. Thus, the “Direct 20

    Billing” method is appropriate because it assigns costs in accordance with cost 21

    causation and benefits received. For the work orders that assign costs using 22

    Direct Billing, the per unit amounts charged by XES to SPS are no higher than the 23

    RR10 - Page 225 of 502 04593

  • Bellinghausen Direct – Revenue Requirement Page 30

    unit amounts billed by XES to other affiliates for the same or similar services and 1

    represent the actual costs of the services. 2

    Q. Why is it appropriate to allocate costs based upon the “Electric Transmission 3

    Plant” method for the costs captured in the work orders that uses that billing 4

    method? 5

    A. For the Work Orders that use the “Electric Transmission Plant” method as the 6

    allocator, the costs are driven by the transmission assets of all of the Operating 7

    Companies. For example, Work Order 442, which captures the labor costs 8

    associated with developing standards, evaluating performance, and establishing 9

    criteria for maintaining transmission plant assets of all of the Operating 10

    Companies, uses the “Electric Transmission Plant Asset” method as the allocator. 11

    Thus, the costs in this work order are allocated among the Operating Companies 12

    based on each Operating Company’s proportionate share of total Operating 13

    Company transmission plant assets (i.e., the transmission plant assets of a 14

    particular Operating Company as a percentage of the total transmission plant 15

    assets of all of the Operating Companies). This allocation reflects cost causation 16

    and the distribution of the benefits of the services received. For the work orders 17

    that assign costs based upon this billing method, the per unit amounts charged by 18

    XES to SPS as a result of the application of this billing method are no higher than 19

    the unit amounts billed by XES to other affiliates for the same or similar services 20

    and represent the actual costs of the services. 21

    RR10 - Page 226 of 502 04594

  • Bellinghausen Direct – Revenue Requirement Page 31

    Q. You have covered the billing methods used to bill 98.55% of the costs 1

    associated with this affiliate class. Why have you not specifically covered the 2

    remaining 1.45% of the costs of this class? 3

    A. I have described the predominant billing methods associated with this affiliate 4

    class. The remaining costs are billed using 10 different allocators, no one of 5

    which is used to bill more than 0.9% of the costs. In light of the number of 6

    remaining allocators, work orders, and relative dollar amounts, I have not gone 7

    into a detailed discussion of these other billing methods in order to keep the 8

    discussion to a manageable level. The work orders and billing methods used to 9

    charge the remaining 1.45% of the costs in this class, however, are presented in 10

    my Attachment ALB-RR-B, discussed earlier. A reader may reference that 11

    attachment and then refer to the specific work order summary provided in Ms. 12

    Schmidt-Petree’s Attachment JSSP-RR-14 for an explanation of the particular 13

    allocators used and the cost drivers for the activities reflected in that particular 14

    work order. 15

    Q. Have you determined that the costs reflected in the remaining 1.45% of costs 16

    associated with this class of services have been billed using an appropriate 17

    billing method? 18

    A. Yes. I have reviewed each of the work orders and the associated allocators used 19

    to bill the remaining 1.45% of the costs of this class. The cost drivers reflected in 20

    the billing method used to bill the costs of each work order are consistent with 21

    and reflect the cost drivers of the services captured in each particular work order. 22

    Therefore, the billing methods are appropriate because the allocation of costs is in 23

    RR10 - Page 227 of 502 04595

  • Bellinghausen Direct – Revenue Requirement Page 32

    accordance with the distribution of the benefits received by SPS and are no higher 1

    than the per unit costs charged to other affiliates for the same or similar types of 2

    services. 3

    RR10 - Page 228 of 502 04596

  • Bellinghausen Direct – Revenue Requirement Page 33

    IV. CONCLUSION 1

    Q. Were Attachments ALB-RR-1, and ALB-RR-A through ALB-RR-D 2

    prepared by you or under your direct supervision and control? 3

    A. Yes, as to Attachment ALB-RR-1. Attachments ALB-RR-A through ALB-RR-D 4

    were prepared by Ms. Schmidt-Petree and her staff. I and my staff have reviewed 5

    these attachments and I believe them to be accurate. The same information is 6

    presented in Ms. Schmidt-Petree’s Attachments JSSP-RR-A through JSSP-RR-D 7

    and the information is attached to my testimony for the convenience of those 8

    reviewing my testimony. 9

    Q. Does this conclude your pre-filed direct testimony? 10

    A. Yes. 11

    RR10 - Page 229 of 502 04597

  • RR10 - Page 230 of 502 04598

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    Attachment ALB-RR-A Page 1 of 2

    Docket No. 43695

    RR10 - Page 232 of 502 04600

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    Attachment ALB-RR-A Page 2 of 2

    Docket No. 43695

    RR10 - Page 233 of 502 04601

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    18

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    19

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    20

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    21

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    22

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    23

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    24

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    28

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    29

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    -

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    -

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    35

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    36

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    37

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    38

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    39

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    40

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