# Control Number: 42004

Item Number: 333
Addendum StartPage: 0^ ^,-•.



### SOAH DOCKET NO. 473-14-1665 14 APR - 7 PM 4: 29 DOCKET NO. 42004 l'udL Ic x= =j I, ^ APPLICATION OF SOUTHWESTERN § PUBLIC SERVICE COMPANY FOR § AUTHORITY TO CHANGE RATES AND § TO RECONCILE FUEL AND § PURCHASED POWER COSTS FOR THE § PERIOD JULY 1, 2012 THROUGH § JUNE 30, 2013 § 

## , " ^ FILING BEFORE THE STATE OFFICE

OF

ADMINISTRATIVE HEARINGS SOUTHWESTERN PUBLIC SERVICE COMPANY'S

RESPONSE TO SIERRA CLUB'S FIRST REQUEST FOR INFORMATION QUESTION NOS. 1-1 THROUGH 1-49 (Filename: SPSRespSierralst.doc; Total Pages: 207) 

### I. WRITTEN RESPONSES ................................................................................................... 3 II. INSPECTIONS .

.................................................................................................................. 4 RESPONSES

................................................................................................................................. 7 QUESTION NO. SIERRA CLUB 1-1 : ................................................................. QUESTION NO. SIERRA CLUB 1-2: ................................................................. QUESTION NO. SIERRA CLUB 1-3: ................................................................. QUESTION NO. SIERRA CLUB 1-4: ................................................................. 

### QUESTION NO. SIERRA CLUB 1-5: ................................................................. QUESTION NO. SIERRA CLUB 1-6: ................................................... QUESTION NO. SIERRA CLUB 1-7: ................................................... QUESTION NO. SIERRA CLUB 1-8: ................................................... QUESTION NO. SIERRA CLUB 1-9: ................................................... QUESTION NO. SIERRA CLUB 1-10 : ................................................. QUESTION NO. SIERRA CLUB 1-11 : ................................................. QUESTION NO. SIERRA CLUB 1-12 : ................................................. QUESTION NO. SIERRA CLUB 1-13 : ................................................. QUESTION NO. SIERRA CLUB 1-14 : ................................................. QUESTION NO. SIERRA CLUB 1-15 : ................................................. QUESTION NO SiERRA CLUB 1-16* ........................ 7

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........................ 9 ...................... 10 ...................... 11 ...................... 12 ...................... 13 

### ................................... 16 ................................... 17 ................................... 18

............................................................ QUESTION NO. SIERRA CLUB 1-17 : ............................................................ ...................... 19

...................... 20

...................... 21

...................... 22

...................... 23

...................... 24

...................... 26

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company'sResponse to

Sierra Club's FirstRequest for Information

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# 5-53

### QUESTION NO. SIERRA CLUB 1-18 ........................................................................................ 30 QUESTION NO. SIERRA CLUB 1-19 ........................................................................................ 32 QUESTION NO. SIERRA CLUB 1-20: ........................................................................................ 33 QUESTION NO. SIERRA CLUB 1-21: ........................................................................................ 34 QUESTION NO. SIERRA CLUB 1-22: ........................................................................................ 35 QUESTION NO. SIERRA CLUB 1-23: ........................................................................................ 36 QUESTION NO. SIERRA CLUB 1-24: ........................................................................................ 38 QUESTION NO. SIERRA CLUB 1-25: ........................................................................................ 39 QUESTION NO. SIERRA CLUB 1-26: ........................................................................................ 41 QUESTION NO. SIERRA CLUB 1-27: ........................................................................................ 42 QUESTION NO. SIERRA CLUB 1-28: ........................................................................................ 44 QUESTION NO. SIERRA CLUB 1-29: ........................................................................................ 45 QUESTION NO. SIERRA CLUB 1-30: ........................................................................................ 46 QUESTION NO. SIERRA CLUB 1-31 ........................................................................................ 47 QUESTION NO. SIERRA CLUB 1-32: ........................................................................................ 48 QUESTION NO. SIERRA CLUB 1-33: ........................................................................................ 

### 49 QUESTION NO. SIERRA CLUB 1-34: ........................................................................................ 50 QUESTION NO. SIERRA CLUB 1-35: ........................................................................................ 51 QUESTION NO. SIERRA CLUB 1-36: ........................................................................................ 52 QUESTION NO. SIERRA CLUB 1-37: ........................................................................................ 53 QUESTION NO. SIERRA CLUB 1-38: ........................................................................................ 54 QUESTION NO. SIERRA CLUB 1-39: ........................................................................................ 55 QUESTION NO. SIERRA CLUB 1-40: ........................................................................................ 56 QUESTION NO. SIERRA CLUB 1-41 ........................................................................................ 57 QUESTION NO. SIERRA CLUB 1-42: ........................................................................................ 58 QUESTION NO. SIERRA CLUB 1-43: ........................................................................................ 59 QUESTION NO. SIERRA CLUB 1-44: ........................................................................................ 60 QUESTION NO. SIERRA CLUB 1-45: ........................................................................................ 61 QUESTION NO. SIERRA CLUB 1-46: ........................................................................................ 62 QUESTION NO. SIERRA CLUB 1-47: ........................................................................................ 63 QUESTION NO. SIERRA CLUB 1-49: ........................................................................................ 64 CERTIFICATE OF SERVICE

................................................................................................. 65 EXHIBITS ATTACHED: Exhibit SPS-Sierra Club 1-5.1 (non-nativeformat ............................................................ 66 Exhibit SPS-Sierra Club 1-5.2 (non-nativeformat) ............................................................... 72 Exhibit SPS-Sierra Club 1-11 (non-nativeformat) ................................................................ 76 

### Exhibit SPS-Sierra Club 1-17(f) ( filename: SPS-Sierra Club 1-17(f).xls) ..........................151 Exhibit SPS-Sierra Club 1-17(q) (non-nativeformat) .........................................................184

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information

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### SOAH DOCKET NO. 473-14-1665 DOCKET NO. 42004 APPLICATION OF SOUTHWESTERN § PUBLIC SERVICE COMPANY FOR § AUTHORITY TO CHANGE RATES AND § TO RECONCILE FUEL AND § PURCHASED POWER COSTS FOR THE § PERIOD JULY 1, 2012 THROUGH § JUNE 30, 2013 § BEFORE THE STATE OFFICE

OF

ADMINISTRATIVE HEARINGS

SOUTHWESTERN PUBLIC SERVICE COMPANY'S

RESPONSE TO SIERRA CLUB'S FIRST REQUEST FOR INFORMATION QUESTION NOS. 1-1 THROUGH 1-49 Southwestern Public Service Company ("SPS") files this response to Sierra Club's ("Sierra Club") First Request for Information, Question Nos. 1-1 through 1-49. 

### 1. WRITTEN RESPONSES SPS's written responses to Sierra Club's First Request for Information are attached and incorporated by reference. Each response is stated on or attached to a separate page on which the request has been restated. SPS's responses are made in the spirit of cooperation without waiving SPS's right to contest the admissibility of any of these matters at hearing. In accordance with P.U.C. PROC. R. 22.144(c)(2)(A), each response lists the preparer or person under whose direct supervision the response was prepared and any sponsoring witness. When SPS provides certain information sought by the request while objecting to the provision of other information, it does so without prejudice to its objection in the interests of narrowing discovery disputes under P.U.C. PROC.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's FirstRequest for Information

- 3-R. 22.144(d)(5). As allowed underP.U.C. PROC. R. 22.144(c)(2)(F), SPS stipulates that its responses may be treated by all parties as if they were made under oath. 

### II. INSPECTIONS. If responsive documents are more than 100 pages but less than eight linear feet in length, the response will indicate that the attachment is voluminous ("(V)") and, pursuant to P.U.C. PROC. R. 22.144(h)(2), the exhibit will be made available for inspection at SPS's voluminous room at 401 Congress Avenue, Suite 2100, Austin, Texas 78701; telephone number (512) 370-2867. Voluminous exhibits will also be provided on CD to any requestingparty. Further, SPS will upload all voluminous documents, along with all native files for review to SPS's Sharepoint website: https://collaboration.xcelenergy.com/sps/SPSFinalRateCases/default.aspx All parties will be provided a log in id number at time of intervention to access the Sharepoint
website. If a response or the responsive documents are provided pursuant to the protective order in this docket, the response will indicate that it or the attachment is either confidential ("CONF") or highly
Sensitive ("HS") as appropriate under the protective order. Confidential and Highly Sensitive materials will be served on all parties that have signed and filed the certification under the protective order entered in this docket. Confidential and Highly Sensitive responsive documents will also be made available for inspection at SPS's voluminous room, unless they form a part of a response that exceeds eight linear feet in length; then they will be available at their usual repository in accordance

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern PublicService Company'sResponse to Sierra Club's First Requestfor Information

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### with the following paragraph. Please call in advance for an appointment to ensure that there is

sufficient space to accommodate your inspection. 

### If responsive documents exceed eight linear feet in length, the response will indicate that the attachment is subject to the FREIGHT CAR DOCTRINE, and, pursuant to P.U.C. PROC. R. 22.144(h)(3), the attachment will be available for inspection at its usual repository, SPS's offices in Amarillo, Texas, unless otherwise indicated. SPS requests that parties wishing to inspect this 

### material provide at least 48 hour notice of their intent by contacting Ron Moss of WinsteadP.C., 401 Congress Avenue, Suite 2100, Austin, Texas 78701; telephone number (512) 370-2867; facsimile transmission number (512) 370-2850; email address rhmoss@winstead.com. Inspections will be 

### scheduled to accommodate all requests with as little inconvenience to the requesting party and to SPS's operations as possible.

XCEL ENERGY SERVICES INC. 

### Stephen Fogel State Bar No. 07202010 Matthew P. Loftus State Bar No. 24052189 

### 816 Congress Avenue, Suite 1650 Austin, Texas 78701-2471 Office: (512) 478-7267 Facsimile: (512) 478-9232 e-mail: stephen.e.fogel@xcelenergy.com e-mail: matthew.p.loftus@xcelenergy.com 

### Respectfully submitted,

WINSTEAD P.C. Ron H. Moss 

### State BarNo. 14591025. 401 Congress Avenue, Suite 2100 Austin, Texas 78701 Office: (512) 370-2867 Facsimile: (512) 370-2850 e-mail: rhmoss@winstead.com

PUC Docket No. 42004 5OAH DocketNo. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's First Request for Information - 5-GRAVES, DOUGHERTY, HEARON &MOODY P.C.



### Thomas B. Hudson, Jr. State Bar No. 10168500 401 Congress Avenue, Suite 2200 Austin, Texas 78701 Office: (512) 480-5740 Facsimile: (512) 480-5840 e-mail: thudson@gclhtn.com COURTNEY, COUNTISS, BRIAN & BAILEY, LLP 

### Amy M. Shelhamer State Bar No. 24010392 600 S. Tyler, Suite 1700 Amarillo, Texas 79101 Office: (806) 372-5569 Facsimile: (806) 372-9761 

### e-mail: ashelhamer@courtneylawi"imi.com.

BY: ATTORNE"F SOUTHWESTERN PUBLIC SERVICE COMPANY

l'UC Docket Na. 42004 xS'UAH Docket No. 473-14-1465 Southwestern Public Service Conrpany'sResponse to

Sierra Clubs First Reqttestfor Information - 6-

### RESPONSES

QUESTION NO. Sierra Club 1-1: Please provide all work papers and documents supporting the filed direct testimony of each witness filing testimony on your behalf in this proceeding, in electronic format to the extent possible. 

### RESPONSE: The filed direct testimony and attachments, including all work papers, for each of SPS's witnesses were included in PDF form on the Public CD and in native, electronic format on the Native CD provided in the initial filing. Preparer: Brooke Trammell Sponsor: David T. Hudson

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company'sResponse to Sierra Club's First Request for Information

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### QUESTION NO. Sierra Club 1-2: Please provide copies of SPS's responses to all other data requests submitted by parties in this proceeding. This is an ongoing request; please supplement this response as future data responses become available. 

### RESPONSE: Sierra Club has been provided access to all public responses to data requests through SPS SharePoint website. Sierra Club has been provided confidential and highly sensitive documents under the terms of the protective order entered in this case. Preparer: Brooke Trammell Sponsor: David T. Hudson

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information

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### QUESTION NO. Sierra Club 1-3: Please provide a non-redacted, full color or original digital copy of any long term energy plans developed and/or filed in Texas by SPS between 2008 and 2014. 

### RESPONSE: Sierra Club has agreed to extend the time to respond to this question until April 17, 2014.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company'sResponse to

Sierra Club's First Requestfor Information - 9-

### QUESTION NO. Sierra Club 1-4: Please provide the following data for the Company over the longest forward-going analysis period in this filing:

a. Annual summer peak load b. Annual energy requirements
c. Annual capacity reserve requirements d. Annual planning reserve margin 

### RESPONSE: Sierra Club has agreed to extend the time to respond to this question until April 17, 2014.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Requestfor Information -10-

### QUESTION NO. Sierra Club 1-5: Please provide the following data for the Company from 2000 to present:

a. Annual summer peak load b. Annual energy requirements

c. Annual capacity reserve requirements d. Annual planning reserve margin 

### RESPONSE: Sierra Club has clarified that it is requesting information related only to SPS. a., c., d. The information covering January 1, 2009 through June 30, 2013, can be found in

SPS's Schedule 0-1.5 (columns 6, 10, and 11 respectively) (Vol. SCH5, page 215 - 216 of 393) as part of the rate filing package in this docket. Please refer to Exhibit SPS-Sierra Club 1-5.1 for the information covering January 1, 2004 through December 31, 2008. The information in Schedule 0-1.5 and the exhibit is given on a monthly basis, but annual numbers can be determined by looking at the data from the month with the highest System Peak Demand.
b. The information covering the Test Year can be found in SPS's Schedule H-12.1

(Vol. SCH2, Page 183 of 469) as part of the rate filing package in this docket. Please refer to Exhibit SPS-Sierra Club 1-5.2 for information covering January 1, 2006 through June 30, 2012. SPS will supplement this response with the remaining data on or before April 17, 2014. Preparer: Bennie F. Weeks Sponsor: Bennie F. Weeks

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information -11-

### QUESTION NO. Sierra Club 1-6: This question was filed confidentially. 

### RESPONSE: Sierra Club has withdrawn this question.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company'sResponse to

Sierra Club's FirstRequestfor Information - 12-

### QUESTION NO. Sierra Club 1-7: Please describe current demand-side management (DSM) programs offered by SPS and Xcel, including demand-response, interruptible load, and efficiency programs. Please note the customer class and sector, first year or lifetime cost (specify), MW or MWh reductions, expected life, and penetration of these programs. 

### RESPONSE: Sierra Club has clarified that it is only requesting information related to SPS. The following table shows information filed with SPS's 2014 Energy Efficiency Plan and Report ("EEPR"). Because SPS does not specifically forecast participation, it has provided 2013 values below. SPS does not calculate penetration of the programs. The programs are included in SPS's EEPR each year, and SPS intends to continue offering the programs.

Customer Class and Program kW (savings) kWh

(savings) 1 st Year

Program Cost Commercial 5,465 7,629,376 $1,642,650 Commercial & Industrial SOP 1,900 4,993,200 $1,022,245 Small Commercial SOP 301 659,920 $128,634 Load Management SOP 3,000 0 $170,754 Retro-Commissioning MTP 264 1,976,256 $321,017 Residential 1,035 1,812,524 $647,726

Residential SOP 1,035 1,812,524 $647,726 Hard-to-Reach 712 1,246,840 $745,624

Hard-to-Reach SOP 592 1,036,600 $404,117 Low-Income Weatherization 120 210,240 $341,507 Research and Development 0 0 $260,000 Evaluation, Measurement & Verification 0 0 $108,000 Total Annual Projected Savings 7,212 10,688,740 $3,405,000



### PROGRAM DESCRIPTIONS Interruptible load SPS's Interruptible Credit Option ("ICO") tariff implements a load management program that is offered to large commercial and industrial customers who take service under the Large

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information -13-General Service Transmission rate schedules at voltages of 69 kilovolt and above. When a customer opts to take service under the tariff, SPS acquires the right to interrupt a specified amount of the customer's load to limit system demand. As such, it is a type of demand-side resource that can assist in meeting SPS's forecasted peak demand by reducing that demand. 

### Saver's Switch® Saver's Switch® is a demand response product that offers residential participants an annual bill credit as an incentive for allowing SPS to control operation of their central air conditioners on days when the system is approaching its peak. This product is generally utilized on hot summer days.
Energy efficiency programs Commercial Standard Offer Program The Commercial SOP has two components. The Large Commercial component of the Commercial SOP targets commercial customers with single-meter demand of 100 kW or more or aggregate meter demand of 250 kW or more. Incentives are paid to project sponsors for certain measures installed in new or retrofit applications that provide verifiable demand and energy savings. The Small Commercial component targets commercial customers with a single-meter demand of less than 100 kW or with a demand less than 250 kW for the sum of commonly-owned meters. Incentives are paid to project sponsors for measures installed in new or retrofit applications that provide verifiable demand and energy savings. The Small Commercial and Large Commercial incentives and savings are tracked and reported separately. Load Management Standard Offer Program The SPS Load Management Pilot SOP was developed in 2012 in accordance with P.U.C. SUBS'r. R. 25.181, which authorizes participating project sponsors (customers or third-party sponsors) to provide on-call, voluntary curtailment of electric consumption during peak demand periods in return for incentive payments. Incentives are based on verified demand savings that occur at SPS distribution sites taking primary or secondary service or at eligible institutional customers' sites as a result of calls for curtailment. Customers are not required to produce a specific level of curtailed load, but they will receive payments for only the amount of load curtailed. Residential Standard Offer Program The Residential SOP provides incentives to service providers for retrofit and new construction installations of a wide range of residential measures that provide verifiable demand and energy

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information -14-savings. This program has two components, one for single-family residences and one for multifamily residences. Hard-To-Reach Standard Offer Program Hard-To-Reach customers are defined by P.U.C. SuBST. R. 25.181(c)(16) as customers with an annual household income at or below 200% of federal poverty guidelines. The Hard-To-Reach SOP provides incentives for the comprehensive retrofit installations of a wide range of measures that reduce demand and save energy. This includes certain measures with less than a 10-year life (e.g., Compact Fluorescent Lights). This program is split into two segments, one for single-family residences and one for multi-family residences. Low-Income Weatherization Program SPS's Low-Income Weatherization program, offered in accordance with Docket No. 13827, is designed to cost-effectively reduce the energy consumption and energy costs of SPS's low-income customers using the General Guidelines revised to conform with the Final Order in Docket No. 34630. Under this program, one or more program implementers contract with sub-recipients and other not-for-profit community action and government agencies to provide weatherization services to residential SPS customers who meet the current Department of Energy income-eligibility guidelines. Customers must also have electric air conditioning to be eligible for the program. Implementation of SPS's Low-Income Weatherization program provides eligible residential customers appropriate weatherization measures and basic on-site energy education and satisfies the requirements of P.U.C. SuBS'r. R. 25.181(r). Retro-Commissioning Market Transformation Pilot Program The Retro-Commissioning Market Transformation Pilot Program is a program designed for identifying and implementing low-cost/no-cost measures to optimize and enhance existing facility systems by improving performance, reducing peak demand (kW), and saving energy (kWh). The program caters to facilities with significant savings potential, which typically requires a minimum of 50,000 square feet of conditioned space. Preparer: Shawn M. White Sponsor: Shawn M. White

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's FirstRequest for Information

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### QUESTION NO. Sierra Club 1-8:Please describe proposed DSM programs to be offered by SPS and Xcel, including demandresponse, interruptible load, and efficiency programs. Please note the customer class and sector, first year or lifetime cost (specify), MW or MWh reductions, expected life, and penetration of these programs. 

### RESPONSE: Sierra Club has clarified that it is requesting information related only to SPS. SPS is not proposing additional demand-side management ("DSM") programs in 2014. Please refer to SPS's response to Question No. Sierra Club 1-7 for the DSM programs that SPS currently offers. Preparer: Shawn M. White Sponsor: Shawn M. White

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Requestfor Information -16-

### QUESTION NO. Sierra Club 1-9: Please describe if or how existing DSM programs are incorporated into the current case, and provide workpapers showing such, if applicable. 

### RESPONSE: Reductions in Test Year kWh sales and peak demand as a result of SPS's energy efficiency measures and demand response programs are reflected in kWh and peak demand billing determinants for each rate class in the Test Year. Absent these programs, kWh sales would have been higher during the Test Year. Please refer to Exhibit SPS-AXM 12-2(c) for SPS's most recent Load and Resources table. As described in the Direct Testimony of Shawn M. White (Vol. RR11, pages 436-437 of 497), SPS removes the costs of administrative and program costs related to SPS's energy efficiency programs from base rates as SPS received approval to implement an Energy Efficiency Cost Recovery Factor pursuant to P.U.C. SUBST. R. 25.181. SPS's base rates include the costs associated with its Saver's Switch® program and residential demand 

### response program. Preparers: Shawn M. White, Richard M. Luth, Bennie F. Weeks Sponsors: Shawn M. White, Richard M. Luth, Bennie F. Weeks

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information -17-

### QUESTION NO. Sierra Club 1-10: Please describe if or how proposed DSM programs are incorporated into the current case, and provide workpapers showing such, if applicable. 

### RESPONSE: Not applicable. Please refer to SPS's response to Question No. Sierra Club 1-9. Preparer: Shawn M. White Sponsor: Shawn M. White

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information -18-

### QUESTION NO. Sierra Club 1-11: Please provide any DSM potential studies performed by or for SPS and/or Xcel in the last five years, including attendant workbooks or calculations.

a. Please describe if or how these studies are incorporated into the current case. b. If they are not, why not? 

### RESPONSE: Sierra Club has clarified that it is requesting information related only to SPS. a.-b. SPS has performed a DSM potential study for its New Mexico retail service area. Please refer to Exhibit SPS-Sierra Club 1-11. The result of this study is not incorporated into the current case because it applies only to SPS's New Mexico DSM programs. SPS has not performed a DSM potential study for its Texas retail service area because the goals for Texas are prescribed by the Commission. Preparer: Shawn M. White Sponsor: Shawn M. White

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information -19-

### QUESTION NO. Sierra Club 1-12: Please provide a copy of any transmission adequacy studies performed by or for the Company over the past three years. 

### RESPONSE: Sierra Club has clarified that it is requesting information related only to SPS. SPS does not perform its own system-wide transmission adequacy studies. Instead, SPS participates in the SPP Integrated Planning Process ("ITP") studies that address both short-term and long-term reliability needs of SPS and other member systems. The SPP website contains the ITP Near Term, which addresses planning years 1 through 6; the TTP10, which addresses the tenth planning year; and the ITP20, which addresses the twentieth planning year. Those document can be found at the following website: http://www.spp.org/section.asp?pageID=128 Preparer: John S. Fulton Sponsor: John S. Fulton

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Requestfor Information - 20-

### QUESTION NO. Sierra Club 1-13: Are any of the Environmental Retrofit Units subject to reliability must run requirements?

a. If so, please specify which units and provide supporting documentation and analyses. 

### RESPONSE:
No. Preparer: Bennie F. Weeks Sponsor: Bennie F. Weeks

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company'sResponse to

Sierra Club's First Request for Information - 21-

### QUESTION NO. Sierra Club 1-14: Please identify any transmission grid upgrades or changes that would be needed to permit the retirement of any of the Environmental Retrofit Units, and produce any analysis regarding the need for upgrades or changes. 

### RESPONSE: SPS has not performed transmission impact or reliability studies related to the retirement of Harrington and Tolk Stations. 

### Preparer: John S. Fulton Sponsor: John S. Fulton

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information - 22-

### QUESTION NO. Sierra Club 1-15: Please provide a copy of FERC Form 715 information, including all submitted data, filed by or on behalf of SPS for each of the last three years. 

### RESPONSE: Aside from the information in Part 1, which is essentially the cover page of the form, the information contained in the other parts of SPS's FERC Form 715 is considered Critical Energy Infrastructure Information ("CEII") by FERC, and therefore SPS cannot provide copies of the form. FERC requires parties who wish to review CEII information to submit a request for the information, and FERC must review and approve that request. Directions on how to request CEII information can be found here: http://www.ferc.gov/help/filing-guide/ceii-request. asp In addition, SPS obtains the data used to prepare the FERC Form 715 from the Southwest Power Pool ("SPP") subject to a non-disclosure agreement ("NDA") with SPP. Pursuant to the NDA, SPS cannot release any of the information used in the FERC Form 715 to a third party without SPP's permission, and SPS does not have permission to release that information to Sierra Club. Preparer: Brooke Trammell Sponsor: John S. Fulton

PUC Docket No. 42004 SDAH Docket No. 473-14-1665 Southwestern Public Service Company'sResponse to Sierra Club's FirstRequest for Information

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### QUESTION NO. Sierra Club 1-16: State whether SPS has examined the impact on capacity adequacy, transmission grid stability, transmission grid support, voltage support, or transmission system reliability if SPS were to retire or idle the Environmental Retrofit Units in 2015, 2016, or 2017.



### a. If so, identify: i. Any such impact. 

### ii. The cost of remediating each such impact. iii. The time it would take to remediate each such impact. b. If not: i. Explain why not. ii. Identify any studies or analyses that SPS believes would be needed to identify any such impacts. iii. Identify when the Company anticipates it would know such impacts, and under what circumstances such impacts would occur. 

### RESPONSE: No. SPS has not examined the impact on capacity adequacy, transmission grid stability, transmission grid support, voltage support, or transmission system reliability if SPS were to retire or idle Tolk and Harrington in 2015, 2016, or 2017. Please refer to SPS's response to Question No. Sierra Club 1-14.

a.



### b. i. - ii. Not applicable.

i. SPS did not study this scenario since it would not be feasible to procure sufficient capacity to replace the generation from Harrington and/or Tolk in the near term (i.e., 2015-2017).
ii. If SPS were to simulate the removal of Harrington and Tolk in various powerflow and stability studies, it would have to have alternate generation to replace the generation that would have been provided by Tolk and Harrington. If SPS had no other generation to meet the load in 2015-2017 or could not import sufficient power levels to show removal of the proposed

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Requestfor Information

- 24-level of generation, then it would be meaningless to evaluate the idling or retirement of Tolk and Harrington in 2015-2016.
iii. SPS would need to conduct the study before it could determine the impacts. Preparer: John S. Fulton Sponsor: John S. Fulton

PUC DocketNo. 42004 SOAH DocketNo. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information - 25-

### QUESTION NO. Sierra Club 1-17: For each of the Environmental Retrofit Units:

a. Provide the annual forced outage rate from 2009 to 2014 (inclusive). b. Provide the average annual capacity factor from 2009 to 2014 (inclusive).
c. Provide the anticipated annual capacity factor for the remaining life of each unit. d. Identify the retirement date assumed in the Company's filing. e. Identify the remaining book life assumed in the Company's filing. f. Identify the current undepreciated book value, and the expected undepreciated book value for each year of the remaining operating life of the units. g. Identify the current salvage value, and the expected salvage value for each year of the remaining operating life of the units. h. Produce the most recent depreciation study. i. Produce the most recent condition or performance assessment. j. Produce the most recent retirement, continued unit operation, or life extension study or analysis. k. Produce any analysis or assessment of the economics of continued operation of such units. 1. Produce any analysis or assessment of the need for the continued operation of each units. in. Produce any analysis or assessment of the need for and cost of necessary or potentially necessary capital additions to any unit.
n. For all capital additions identified in subpart in, identify the year that the Company expects to begin those capital additions and when it intends to recover for those capital additions.
o. Produce any analysis or assessment of the risks of continued operation of the units. p. Provide the total historic and projected annual water usage in million tons per year. q. Identify the source of water consumed and provide any contracts for water use associated with each unit.
r. Provide the name, location, and capacity of all surface impoundments. i. Please state the percentage of coal combustion byproducts from each
PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company'sResponse to Sierra Club's First Requestfor Information - 26-unit that goes to each one of these impoundments. ii. Please describe how each of these impoundments is lined and any leachate collection systems. 

### RESPONSE: Sierra Club has clarified that it is requesting information related only to SPS.

a. Please refer to SPS's response to Question No. AXM 3-64, Exhibit SPS-AXM 3-64.2. b. Please refer to SPS's response to Question No. AXM 3-64, Exhibit SPS-AXM 3-64.2.

c. SPS has requested an extension until April 18, 2014 to respond to this question. d. The retirement dates assumed in this filing for Harrington Station are:

Harrington Unit 1 - 2036; Harrington Unit 2- 2038; and Harrington Unit 3 - 2040. The retirement dates assumed in this filing for Tolk Station are: 

### Tolk Unit 1 - 2042; and Tolk Unit 2 - 2045. Please refer to Appendix D of Attachment DAW-RR-2 to the Direct Testimony of Dane A. Watson (Vol. RR3, page 111 of 509).

e. Please refer to Appendix A of Attachment DAW-RR-2 to the Direct Testimony of Dane A. Watson (Vol. RR3, page 85-89 of 509) for remaining book life assumed in this filing for Harrington and Tolk. f. Please refer to Exhibit SPS-Sierra Club 1-17(f). The computations in Exhibit SPS-Sierra Club 1-17(f) assume the allocated reserves and net salvage parameters proposed by SPS witness Dane A. Watson. Please note that this

PUC DocketNo. 42004 SOAH DocketNo. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information - 27-does not include any additions that may take place after the end of the test year as well as any retirements, or interim removal cost that may occur when assets are replaced. Even though the net book value of the assets becomes negative at a certain point in the life of the unit, the depreciation reserve also includes negative 5 percent net salvage for the terminal dismantling costs for each unit.
g. Please refer to Exhibit SPS-Sierra Club 1-17(f). h. Please refer to Attachment DAW-RR-2 to the Direct Testimony of Dane A. Watson (Vol. RR3, page 11-150 of 509) for SPS's proposed depreciation study in this docket. i. Sierra Club has agreed to extend the time to respond to this question until April 17, 2014. j. Please refer to Attachment DAW-RR-2 to the Direct Testimony of Dane A. Watson (Vol. RR3, page 11-150 of 509) for SPS's retirement and continued unit operation analysis. SPS has not performed a life extension analysis. k. Sierra Club has agreed to extend the time to respond to this question until April 17, 2014. 

### 1. Sierra Club has agreed to extend the time to respond to this question until April 17, 2014. M. Sierra Club has agreed to extend the time to respond to this question until April 17, 2014.

n. Sierra Club has agreed to extend the time to respond to this question until April 17, 2014.

o. Sierra Club has agreed to extend the time to respond to this question until April 17, 2014.
p. Please refer to the table below for SPS's total historic and projected annual water usage in million tons per year for Harrington and Tolk Stations.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company'sResponse to Sierra Club's First Requestfor Information

- 28-Harrington Station Water Usage (gal) Tolk Station Water Usage (gal)

Year Treated Cooling

Water Treated Boiler

Water Treated Cooling

Water Treated Boiler

Water 2009 4,491,713,982 45,607,480 3,524,527,000 37,345,330 2010 3,849,245,367 45,324,110 3,723,617,500 32,474,700 2011 3,449,796,144 43,664,194 3,379,277,000 32,963,230 2012 3,526,336,970 52,519,660 3,508,038,000 41,823,290 2013 3,359,516,000 52,850,440 3,977,076,000 30,415,440 2014 projection (5 ear average) 3,735,321,693 47,993,177 3,622,507,100 35,004,398

q. The source for water at Harrington Station is primarily effluent water from the City of Amarillo and is used for cooling water. Groundwater is used for high purity boiler water. The source of water for Tolk Station is primarily ground water, some of which comes from Plant X's cooling water. Groundwater is also used for high purity boiler water. Please refer to Exhibit SPS-Sierra Club 1-17(q) for a copy of the contract with City of Amarillo. Sierra Club has withdrawn this question. Preparers: Dean Metcalf, Alan J. Davidson, David A. Low, Bennie F. Weeks, Dane A. Watson Sponsors: Alan J. Davidson, David A. Low, Bennie F. Weeks, Dane A. Watson, Lisa H. Perkett

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information - 29-

### QUESTION NO. Sierra Club 1-18: Reference SPS Application in Docket No. 42004, pg. 20 ("SPS has also requested that it be allowed to recover through fuel costs the costs of certain chemicals needed to meet environmental compliance standards."). Regarding the environmental compliance standards discussed therein, including, but not limited to National Ambient Air Quality Standards (NAAQS), the Regional Haze rule, Mercury and Air Toxics Standards (MATS), Clean Air Interstate Rule (CAIR), the Cross-State Air Pollution Rule (CSAPR), Effluent Limitation Guidelines (ELG), New Source Performance Standards (NSPS), Regional, state, or national Climate Change Initiatives, Water Quality Standards, Coal Combustion Residual (CCR) disposal, in both proposed and finalized or promulgated form:

a. Please list the dollar amount spent by SPS, or any of its utility affiliates, subsidiaries or parent companies, including but not limited to Xcel Energy Inc. on advocacy efforts both to influence public opinion as well as to influence State or Federal officials, regulatory authorities or policymakers though public information campaigns or by providing funding to Public Action Committees or other similar entities for the purposes of discussing or advocating with regard to the above rules. b. Does the Company seek recovery of any of the above-mentioned spending in this rate case? i. If so, please identify the page(s) and line item(s) in Company's Application or Testimony.
c. Does the Company intend to seek recovery of any of the above-mentioned spending in any future rate case in the State of Texas? i. If so, please state when. ii. If the Company does not know a specific date yet, please state the conditions that would be necessary to prompt the Company to seek recovery. d. Has the Company sought recovery of any of the above-mentioned spending in any past rate cases in the State of Texas? i. If so, please state when.
e. Has the Company sought or does the Company intend to seek recovery of the above-mentioned spending in any other past, present or future rate case in any other state? i. If so, please list where and when.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's First Request for Information

- 30-

### RESPONSE:

Sierra Club has clarified that it is requesting information related only to SPS. Sierra Club has agreed to extend the time to respond to this question until April 17, 2014.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's First Request for Information -31-

### QUESTION NO. Sierra Club 1-19: Please provide all reports, memoranda, presentations, or other documents provided to stockholders, investors, banks, investment firms, investment brokers or dealers, investment analysts, bond rating agencies from either SPS or Xcel or the like between 2007 and 2014 (inclusive) including:

a. Environmental compliance status of the Environmental Retrofit Units, b. Past, present or future environmental compliance of the Environmental Retrofit Units,
c. Litigation or settlements concerning the Environmental Retrofit Units, to the extent not covered by attorney-client privilege, d. Past, present or future need for the Environmental Retrofit Units, or the need for or plans for capital additions to the Environmental Retrofit Units, whether for environmental compliance or otherwise, and
e. Any other matter that could affect the future costs or energy output of the Environmental Retrofit Units. 

### RESPONSE: Sierra Club has agreed to limit this response to 2010-2014. Please refer to Exhibits SPS-AXM 4-6(V)(SUPP1) and SPS-AXM 4-6(V)(SUPP1)(CONF), and to Exhibits SPS-TIEC 2-5(V) and SPS-TIEC 2-5(V)(CONF) for the requested information for 2012-2013. SPS will supplement this response with the requested information for 2010, 2011, and 2014. Please refer to the Investors section of the Xcel Energy website for copies of SPS's 10-K, 10-Q, and 8-K Forms. The website can be found here: http://investors.xcelenergy.com/docs.aspx?iid=4025308 Preparer: Kaydra Kirtz Sponsor: Mary P. Schell

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information

- 32-

### QUESTION NO. Sierra Club 1-20: Has the Company prepared or caused to be prepared any study of the Environmental Retrofit Units' (either individually or jointly) vulnerability to drought?

a. If so, please provide such studies and supporting analyses. b. If not, please explain why not. 

### RESPONSE: SPS has not analyzed the units' vulnerability to drought. SPS's Harrington plant primarily utilizes effluent water from the City of Amarillo and the Tolk plant utilizes ground water, and SPS understands that those sources are generally not impacted by drought conditions. Preparer: Dean Metcalf, David A. Low Sponsor: David A. Low

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information - 33-

### QUESTION NO. Sierra Club 1-21: Please provide copies of email and hard-copy correspondence, presentations, and other data provided to or received from the U.S. Environmental Protection Agency, U.S. Department of Justice, the Texas Commission on Environmental Quality (TCEQ), or any combination of those entities regarding the Environmental Compliance Projects or environmental planning for air, water, and solid waste environmental compliance. Provide documentation from January 1, 2007 through 2014, inclusive.

a. If SPS believes any or all of these documents are in the public record, please indicate where the Company believes the documents can be found. 

### RESPONSE: Sierra Club has withdrawn this question.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's First Request for Information - 34-

### QUESTION NO. Sierra Club 1-22: Regarding communications between the Company and TCEQ, provide:

a. Specific notices issued to the Company by TCEQ requiring or requesting a permit for either a particular effluent limit or a specific technology, including, but not limited to both air or water quality permits; b. The Company's applications to TCEQ for said permits and technical documentation supporting the applications.
c. All correspondence between the Company and TCEQ concerning, modifying or clarifying the applications. d. All required air, effluent, and construction permits issued to the Company by TCEQ.
e. Any modifications to those permits requested by the Company or issued by TCEQ, and technical justification for those modifications. f. Is it the Company's belief that the air and effluent permits issued by TCEQ could be fulfilled by the retirement of the generator or boiler at question? i. If no, please describe in detail why retirement of the generator or boiler would not fulfill the relevant permits. 

### RESPONSE: Sierra Club has withdrawn this question.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information -35-

### QUESTION NO. Sierra Club 1-23: For each of the Environmental Compliance Projects included in this filing, please provide:

a. Any other studies conducted by the Company or on behalf of the Company that examine the economic viability of the Environmental Retrofit Units with or without the projects b. A detailed description of each project.
c. An explanation of why the project is required and what it accomplishes. d. The timing and capital costs spending schedule associated with each project.
e. Gant charts for each project (if available). f. For the costs in each year, please state if the costs have been presented to the Texas Public Utility Commission for rate recovery. i. If so, please provide the citation to the docket in which those costs were presented, and the decision of the Commission regarding that specific cost. ii. If not yet, please state when SPS expects to recoup those costs through a rate case. 

### g. The book life of the project. h. Provide studies or reports concerning the suitability and feasibility of technologies or alternatives for environmental compliance considered in the process of selecting the technology for that specific project prior to procuring engineering or design services. i. Provide studies or reports concerning the suitability and feasibility of technologies or alternatives for environmental compliance considered in the process of selecting the technology for that specific project after the procurement of engineering and design services but prior to the start of construction. j. Provide engineering or design reports produced by or for the Company. k. Provide presentations given to the Company board of directors or any other internal review bodies regarding the decision to invest in these projects and memoranda, transcripts, recordings or other notes that memorialized these presentations. 1. A copy of the executed procurement contract. in. The annual variable O&M costs for each project's expected useful life.
n. The annual fixed O&M costs for each project's expected useful life.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information

- 36-o. Any cost modifications approved by the Company's board of directors during or after construction. p. The parasitic or self-use load, in MW, of the environmental upgrade, where applicable. q. The nameplate or projected nameplate capacity of the associated unit prior to and after the project is in-service. 

### RESPONSE: Sierra Club has agreed to extend the time to respond to this question until April 17, 2014.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's First Request for Information - 37-

### QUESTION NO. Sierra Club 1-24: For each of the defined Environmental Compliance Projects, please identify and produce any analysis performed by or on behalf of the Company comparing the cost of continued operation of the unit with retiring and replacing the unit's energy and capacity with any or a combination of any of the following energy resources:



### a. DSM b. Market power purchases
c. Power purchase agreements d. Existing natural gas combined cycle or combustion turbine capacity
e. New natural gas combined cycle or combustion turbine capacity f. Conversion of natural gas combustion turbines to natural gas combined cycle units g. Conversion of any of the Environmental Retrofit Units to natural gas h. Combined heat and power 

### i. Wind j. Solar k. Geothermal 1. Any combination of the above resources 

### RESPONSE: SPS's response to Question No. Sierra Club 1-17(k), when provided, will contain the analysis that SPS conducted regarding the need for requested capital projects. The studies considered natural gas turbine capacity, natural gas combined cycle capacity, and conversion of natural gas combustion turbines to natural gas combined cycle unit capacity. Preparer: Bennie F. Weeks, Alan J. Davidson Sponsor: Bennie F. Weeks, Alan J. Davidson

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern PublicService Company'sResponse to Sierra Club's FirstRequest for Information

- 38-

### QUESTION NO. Sierra Club 1-25: For each of the Environmental Control Projects included in this filing (or planned for the future), please:

a. State whether the Company performed an economic analysis to determine if this was the least cost way to comply with existing and emerging environmental regulations. b. Identify the NPV (or other metric used in decision-making) for each of the Environmental Compliance Projects and any alternatives identified in this filing.
c. Produce any analyses, modeling files, and workpapers (in electronic format with formulas intact) used to calculate the NPV (or other metric used in decision-making) of each of the Environmental Compliance Projects and any alternatives identified in this filing. d. Identify for each year of the analyses used to calculate the NPV (or other metric used in decision-making) of each of the Environmental Compliance Projects and any alternatives identified the value for each of the following inputs used in the economic analysis: i. Energy prices ii. Coal prices iii. Natural gas prices iv. Capacity prices
v. Carbon prices vi. Renewable energy credits vii. Variable O&M viii. Fixed O&M ix. O&M costs to comply with environmental regulations X. Environmental capital costs xi. Non-environmental capital costs xii. Unit dispatch price xiii. Discount rate xiv. Book life
xv. Analysis period (years) xvi. SO2 allowances

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's First Request for Information - 39-xvii. NOxallowances xviii. Nameplate capacity xix. Maximum summer capacity

e. Please provide any analyses used to develop the inputs listed above with supporting workbooks in electronic, machine-readable format with formulas intact. 

### RESPONSE: The Sierra Club has revised the certain parts of this question as follows: For each of the Environmental Control Projects included in this filing (or planned for +h° fit, please:

ix. O&M costs to comply with current and future environmental regulations (differentiated) 

### X. Environmental capital costs, current and planned (differentiated)

a. SPS has not conducted an analysis of whether each Environmental Compliance Project is the least cost way to comply with existing and emerging environmental laws. b. - e. SPS did not conduct the specified analysis and therefore did not calculate an NPV for

the Environmental Compliance Projects. Preparer: Alan J. Davidson Sponsor: Alan J. Davidson

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information

- 40-

### QUESTION NO. Sierra Club 1-26: Did SPS consider any price for carbon emission allowances, taxes, or regulation compliance costs in its economic analysis of the Environmental Compliance Projects?

a. If so, what prices were used? b. Were the prices included in the base case or only in certain sensitivities?
c. If included only in certain sensitivities, identify which sensitivities included those costs and what prices were used? 

### d. Were carbon prices considered with all alternatives? i. If yes, what prices were used with each alternative considered? e. If not, why did SPS not consider any price for carbon? 

### RESPONSE: SPS did not perform an economic analysis of each individual Environmental Compliance Project. Preparer: Dean Metcalf, Alan J. Davidson Sponsor: Alan J. Davidson

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's FirstRequestfor Information

- 41-

### QUESTION NO. Sierra Club 1-27: Regarding the modeling of Environmental Control Projects:



### a. Identify the vendor of the model used to generate the economic analysis results, and provide contact information for the vendor. b. Does the model require a license in order to gain access to raw (i.e., as used) data files?
c. If so, provide a vendor contact who could provide such a license. d. Does the model require a license in order to operate the model?
e. If so, provide a vendor contact who could provide such a license. f. Did an employee of SPS or an outside vendor operate the model? i. If so, please identify the individual or individuals who operate the model at SPS or the identified outside group. g. If SPS uses any other production cost or optimization models or market valuation models aside from the model for this case, please identify those models and their vendors. h. Produce in machine-readable, electronic, digital format, as used by SPS or outside vendors, with protections removed, all input files used in production cost or optimization or market valuation modeling for this case. i. Please identify any changes to the input files that may be required to reproduce modeling for this case. Please specify why such changes are required. j. To the extent that such input files, as used by the Company or an outside vendor, cannot be produced in a commonly accessible format (i.e., text file, spreadsheet, or Access file), produce input files in a commonly accessible format. k. Produce in machine-readable, electronic, digital format, as used by the Company, with protections removed, all output files used in production cost or optimization or market valuation modeling for this case. 1. To the extent that such output files, as used by the Company or an outside vendor, cannot be produced in a commonly accessible format (i.e., text file, spreadsheet, or Access file), produce input files in a commonly accessible format. in. Produce any other files, worksheets, or workpapers used to develop, interpret, or review inputs or outputs of production cost or optimization or market

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information -42-valuation modeling for this case.
n. Please identify the assumptions, including any supporting documentation, that SPS or its agents used in each base case and sensitivity scenario modeled. 

### RESPONSE: Sierra Club has clarified that it is requesting information related only to SPS. SPS has not conducted any modeling of the Environmental Compliance Projects. Preparers: Dean Metcalf, Alan J. Davidson Sponsor: Alan J. Davidson

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Request for Information - 43-

### QUESTION NO. Sierra Club 1-28: Please describe other upgrades or modifications to the Environmental Retrofit Units that might be required to allow these units to operate for the expected service life after the Environmental Control Projects are completed?

a. If there are expected future upgrades, please state when SPS expects to make those modifications and when SPS expects to seek a rate increase to recover costs associated with those modifications. 

### RESPONSE: Sierra Club has withdrawn this request.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to

Sierra Club's First Requestfor Information

- 44-

### QUESTION NO. Sierra Club 1-29: Please state whether the Company has issued a request for proposal (RFP) to identify alternatives to the Environmental Compliance Projects.

a. If SPS issued an RFP, please provide: i. The RFP that was issued by the Company. ii. All responses to the RFP. iii. A citation to the analysis or document in which the investment was

examined, if already provided or in the public record. iv. The analysis or document in which the investment was examined, if not already provided or in the public record.
v. The date upon which the analysis was conducted and the name and department of the individual(s) responsible for conducting the analysis. vi. The date upon which the analysis was reviewed and the name and department of the individual(s) responsible for reviewing the analysis. vii. The date upon which the analysis was accepted or approved and the

name and department of the individual(s) responsible for such approval. viii. If the analysis was not reviewed, accepted or approved, please explain

in detail why not. 

### RESPONSE: SPS did not issue any requests for proposal to identify alternatives to the Environmental Compliance Projects. Preparer: Alan J. Davidson Sponsor: Alan J. Davidson

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company'sResponse to Sierra Club's FirstRequest for Information

- 45-

### QUESTION NO. Sierra Club 1-30: Please provide a list of generation resources that are not under a long-term contract with the Company but could provide energy and capacity supply to the Company, with the nameplate capacity of each resource, for the following types:

a. Natural gas combined-cycle 

### b. Natural gas combustion-turbine c. Solar d. Wind e. Geothermal f. Other renewables besides those listed in (c) through (e). 

### RESPONSE: Sierra Club has withdrawn this question.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company'sResponse to Sierra Club's FirstRequest for Information

-46-

### QUESTION NO. Sierra Club 1-31: Please describe SPS's current and planned efforts to acquire additional capacity with generation resources not previously owned by the Company including:

a. All communications between the Company and the owners of existing generation resources identified in responses b. All offers for the sale of existing resources, or a portion thereof, received by the Company from January 2009 to present. 

### RESPONSE: Sierra Club has clarified that it is requesting information related only to SPS. SPS has no current or planned effort to purchase generation resources not previously owned by SPS. a. - b. No such communications or offers occurred between 2009 and the present. Preparers: Bennie F. Weeks, Alan J. Davidson Sponsors: Bennie F. Weeks, Alan J. Davidson

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's First Request for Information -47-

### QUESTION NO. Sierra Club 1-32: Please provide the following information for the years 2009-2014 (inclusive):

a. Any documents in the possession of SPS regarding the actual construction costs of new wind and solar capacity in ERCOT or the SPS territory. b. A list of all wind and solar energy projects built by SPS.
c. For each such wind and solar energy project, identify: i. Nameplate capacity ii. Capital cost iii. Annual fixed O&M cost iv. Annual variable operating cost
v. Levelized cost of energy ("LCOE") vi. Number of jobs created 

### vii. Tax revenue generated for each year of operation. d. Any documents in the possession of SPS regarding the power purchase price for wind and solar capacity in ERCOT or the SPS territory.
e. All offers for the sale of energy and capacity from wind and solar generation received by the Company. f. A list of all wind and solar energy power purchase agreements entered into by SPS. g. For each such wind and solar energy power purchase agreement, provide: i. A copy ofthe agreement ii. Length of terms of the agreement iii. Annual energy and capacity provided iv. Cost of energy (including cost per megawatt hour and annual escalation)
v. Cost of capacity (including cost per MW-day and annual escalation). 

### RESPONSE: Sierra Club has agreed to extend the time to respond to this question until April 17, 2014.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's First Request for Information - 48-

### QUESTION NO. Sierra Club 1-33: State whether SPS and/or Xcel has prepared or caused to be prepared any study of the costs to bring the Environmental Retrofit Units (either individually or jointly) into compliance with the regulatory options being considered in EPA's proposed effluent limitations guidelines.



### a. If so: i. Identify the costs that were identified ii. State whether such costs were factored into the economic analysis for the Environmental Compliance Projects: 1. If so, explain how 2. If not, explain why not iii. Produce all such studies b. If not, explain why not 

### RESPONSE: Sierra Club has withdrawn this question.

PUC Docket No. 42004 SOAH Docket No. 473-14-1665 Southwestern Public Service Company's Response to Sierra Club's FirstRequest for Information - 49-