- - -

Xcel Energy/USFWS

Avian Protection Memorandum Of Understanding

Semi-Annual Report

- July 30, 2004

Covering January 1, 2004 through June 30, 2004 Reporting Period

On April 19, 2002, Xcel Energy and the USFWS (Service) entered into a Memorandum of

Understanding (MOU) to establish procedures and policies to be employed by the Company's

operating companies and the Service in dealing with migratory birds that may be present, injured or

killed on the Company's property during the period of this MOU.

As part of the agreement, Xcel Energy agreed to file a report three months and two weeks after the

date of the execution of this MOU to the Service compiling the information described above in the

MOU, which occurred during the initial three-month period. The Company submitted the first

report on August 2,2002. One report is submitted on behalf of all the operating companies that

signed the MOU every six months. Since some of the special use permits recently acquired by

several of the Xcel operating companies have January 31, 2004 reporting dates, we have moved up

the reporting date slightly to accommodate both submittal date requirements. We will now provide

reports that cover January 1 through June 30 and July 1 through December 31. The reports will be

filed within 30 days of the final report date.

1. Status of the Development and Implementation of an Avian Protection Plan (APP)

EDM International, Inc. issued the final draft APP for Xcel Energy operating companies Public

Service Company of Colorado (PSCo) and Cheyenne Light Fuel and Power Company (CLFP). The

Company submitted the plan to the USFWS staff on April 30, 2004. USFWS Staff gave verbal

approval of the APP on June 29, 2004.

As reported previously, Xcel Energy is in the process of beginning the APP's for its operating

companies Northern States Power - Wisconsin (NSPW), Northern States Power - Minnesota

(NSPM), and Southwestern Public Service Company (SPS) this year. We met with USFWS staff on

June 29, 2004 to discuss the plan and goals for the APPs for NSPW and NSPM. Those plans will

address electrocutions, but will focus more on collision and osprey nesting management issues. We.

will be meeting again with USFWS staff and other agencies in a few months.

We plan to meet with the USFWS staff for the SPS plan by August 13, 2004. This plan will be

similar to the APP developed for PSCo since the bird management issues are similar.

We expect that the plans will be complete in 2006. As stated in previous reports, regardless of the

completion date of the APP's, Xcel Energy will continue to manage issues that arise with

electrocutions and collisions that occur as the APP's are developed.

Xcel Energy has implemented a training program for all electric delivery field personnel that may

encounter birds. This training program has been underway for almost a year. We plan to review

and update the training plan over the next six months to target additional employees. The training

has been positive and has increased employee awareness of the issues and helped Xcel Energy

employees to know who to call when an issue arises. Xcel Energy is in compliance with Section 4.A.
Xcel Energy/USFWS

Avian Protection Memorandum Of Understanding

Sermi-Annual Report

July 30, 2004

of the other MOUs.

2. Status of Special Purpose Permit

Xcel Energy has filed applications for special purpose permits for all of the operating companies.

Region 3 has issued special Purpose permits for NSPM (Permit MB074020-0) and NSPW (Permit

MB074019-0) and Region 6 for PSCo (Permit MB702651-1) and CLFP (Permit MB793891-0) The

SPS permit (Permit MB082993-0) was received on 02/17/04.

3. Summary of Avian Injuries

None reported for any of the operating companies for this report period.

Operating Description Date Comments

Company

PSCO Great Horned Owl 6/17/04 The owl was injured on a transformer pole in front of an elementary

school in Pierce CO. The injury was reported to PSCo by a third

party. The Rocky Mountain Raptor Program was contacted and

retrieved the injured owL Due to the extent of the injuries, the owl was euthanized. PSCo performed an investigation and has scheduled

the installation of retrofitting measures on the high-risk pole and

adjoining poles.

SPS Great Homed Owl 01/09/04 Amarillo South Substation - not energized. Injured or blind. Game

Warden took the owl to Tumber Creek Vetednary HospitaL The bird

was blind, and for some reason was cuthanized.

4. Summary of Avian Deaths -

The following table summarizes avian deaths that have occurred since December 31, 2003. As noted

in the introduction section, we are changing our reporting period to correspond with our special

purpose permit reporting requirements.

Operating Description Date Comments

Company

NSPM 3 trumpeter swans 1/7/04 Three swans dead as a result of collision with line in same area where

swans were found last year. Swan flight diverters were in the process

of being installed but all had not been completed. SFD installation has

now been completed. Swan carcasses collected by Madeleine Linck,

Trumpeter Swan Society (ISS).

NSPM Great blue heron 3/1/.04 Great blue heron was found dead by a neighbor under the

transmission line in Lake Rebecca Park in Hastings MN. Appeared to

be collision. Area will be reviewed during development of APP to

determine if marking appropriate.

NSPM Trumpeter swan 4-/1/04 Dead swan found by line crew after responding to line interrupts on a

distribution line east of Dayton MN. Bird carcass was lying in marsh

below line and was badly burned. Swan carcass collected by

Madeleine Linck, (rSS). Line marking flappers were installed on 4/2

Page 2 of 5
Xcel Energy/USFWS

Avian Protection Memorandum Of Understanding

Semi-Annual Report

July 30, 2004

Operating Description Date Comments

Company . .

NSPM Trumpeter swan 4/11104 Dead swan found by TSS volunteerdoing an inventory of swans in area around Watertown MN. Bird carcass was lying in field below

line. Swan carcass collected by Madeleine Linck, TSS. Line marking

being evaluated.

NSPW Crow 3/3/04 Crow found dead in Hallie substation, Chippewa Falls, WI. Did not

appear to be electrocuted. Substation win be reviewed in Fall 2004 to

determine if any retrofitting required. Body discarded.

CLF&P Hawk, unknown type 3/24/04 Hawk was electrocuted on transformer pole near Cheyenne, WY.

Carcass was discarded as per Wyoming Fish and Game. Transformer

was retrofitted

CLF&P Hawk, unknown type 7/13/04 Hawk was found near distribution pole near Laramie, WY. Wyoming

Fish and Game took carcass. Investigation is being performed to

determine next action.

PSCo Owl, unknown type 3/2/04 Owl was found in Ennis Substation at the base of a transformer and

discarded as per USFWS. PSCo is in the process of installing

equipment to deter perching.

PSCo Peregrine falcon 3/10/04 Falcon was trained and its tether got caught on a damper near Platteville, CO. USFVCS v.was contacted and accepted carcass. The

falcon was banded. No further action is required.

PSCo Owl, unknown type 3/17/04 Owl was found by a homeowner at the base of a transformermounted pole located near Platteville, CO. Carcass was discarded as

per USFWS and pole w.as retrofitted.

PSCo Great Homed owl 7/12/04 Owl was electrocuted on a pole-mounted transformer near Rifle, CO.

Carcass was discarded as per USFWS. Transformer was retrofitted.

SPS Great Homed Owl 01/05/04 Carcass was discovered at Amarillo, TX, during a one-hour outage.

Carcass was left at base of pole. The transformer was retrofitted on

1/07/04 with poly guards at a cost of approx. $250 counting material

. and crew time.

SPS Rough Legged Hawk 01/19//04 Carcass was discovered at Amarillo, TX, during a 45-minute outage. - Carcass was left atbase of pole. Installing two guards and

corresponding jumpei cable insulation on each transformer, at a cost

of $200, modified the three-transformer bank structure.

SPS Great Homed Owl 02/06/04 Amarillo, Texas: Owl & dead coyote were dumped off at the Randall

County Interchange substation facility, and did not involve any

electrocution. The area is a popular junk drop off. The local Game

Warden, Bill Hasley, was notified, as well as USFW agent Delivan

._ Roper.

SPS Red Tailed Hawk 02/11/04 Stinnett, TX: A dead hawk was discovered during a 1.5-hour outage

of a primary metering station. A line crew from Borger installed 4

animal guards on the bushings and also insulation on some of the

energized risers. There was a nest, possibly from a sparrow, that was

. located on the bottom cross arm. The nest appeared to be too small

to be a hawk's nest. The inactive nest was removed. Not counting

the cost of the cross-arm replacement, which had to be done

regardless of the bird death, we spent about $250 on labor, vehicle,

and materials for the retrofit

SPS Great Hormed Owl 02/15/04 Roundup, TX Carcass was discovered at a substation during a I hour

13 minute outage.

SPS Bald Eagle 04/13/04 Canyon, TX- The eagle had been there for several weeks. A City of

Canyon employee discovered the bird and notified Texas Parks &

Wildlife, who subsequently called Xcel Energy. It appears the area

. has had raptor electrocutions in the past, according to the city of

Page 3 of 5
Xcel Energy/USFWS X

Avian Protection Memorandum Of Understanding

Semi-Annual Report

July 30, 2004

Operating Description Date Comments

Company

Canyon employee. It is adjacent to the waste treatment lagoons,

whi-h attract a large number of geese and ducks. Materials for

modification have been received and arc schedule for installment on

. August 23.

SPS Great Homed Owl 05/10//04 Dumas, TX: Carcass was discovered at the Hartly & Moore County

line, near Dumas, TX. No outage was reported. The transformer was

retrofitted on 07/06/04 by installing 4 poly guards and 4 jumper

insulation covers, at a cost of $250.

SPS Unknown 06/01/04 Dumas, TX: Carcass was discovered during a 4 hour 16 minute

outage. Retrofits induded replacing the solid blades and disconnects

of the structure. The line crew also installed 6 animal guards on the

bushings and insulation on the corresponding energized risers. Repair

costs: $2112.

SPS Great Homed Owl 06/01/04 Borger, TX: Hutchinson County Interchange. The clectrocution

resulted in the failure of capacitors and a reportable PCB oil spill.

SPS Great Horned Owl 01/03/04 Carcass was discovered near Groom, IX, during a one hour 36

minute outage. Carcass was left at base of pole. Retrofit of pole is

being assessed.

5. Summary of Migratory Bird Nest Removals

A. Active Migratory Bird Nests Non-Emergency Removals

None have been reported.

B. Active Nests Of Non-Endangered/Threatened. Non-eagle Migratory Birds-Emergency

Removals

None have been reported

C. Inactive Nests of Non-listed. Non-eagle Migratory Birds -Emergency Removal

With the new FWS policy (Memorandum (MBPM-2) issued April 15 2003) for removal of inactive

nests of non-listed, non-eagle migratory birds, Xcel Energy will no longer report these activities in

this report. We will continue to work with the appropriate state agencies as necessary.

D. Endangered/Threatened Migratory Bird Nest Removals

No removals for this reporting period.

6. Eagle Permits

No requests have been filed.

Page 4 of 5
-

Xcel Energy/USFWS

Avian Protection Memorandum Of Understanding

Semi-Annual Report

July 30, 2004

7. Summary of Record-Keeping Procedures

Each contact for the operating companies is coordinating contacts and reports. Once the special

purpose permits are acquired, final procedures will be completed. All biannual reports submitted to

USFWS are kept on a shared folder for the Company.

S. Next Report Date

The next report will be submitted to the Service within 30 days following December 31, 2004.

\\FNPCPSPOI\Home\w315l4\PROJECTS\APP-MOU-Stuff\July_2004_USFWS-Repon-final.doc

Page 5 of 5