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

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

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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


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


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”).

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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

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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

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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

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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


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

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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


% 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


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


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


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


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.

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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 B —

Affiliate Class


Column C —

FERC Account

The FERC Account for the expense

that has been excluded.

RR10 - Page 211 of 502 04579


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 B —

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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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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Docket No. 43695

RR10 - Page 231 of 502 04599

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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

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

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