HomeMy WebLinkAbout18-3678 ord429
ORDINANCE NO. 18-3678
AN ORDINANCE OF THE CITY OF PLAINVIEW, TEXAS APPROVING A
SETTLEMENT AGREEMENT BETWEEN THE ALLIANCE OF XCEL
MUNICIPALITIES ("AXM") AND SOUTHWESTERN PUBLIC SERVICE
COMPANY ("SPS" OR "COMPANY") REGARDING THE COMPANY'S
STATEMENT OF INTENT TO CHANGE ELECTRIC RATES IN ALL
CITIES EXERCISING ORIGINAL JURISDICTION; REQUIRING
REIMBURSEMENT OF THE CITY'S RATE CASE EXPENSES;
DETERMINING THAT THIS ORDINANCE WAS PASSED IN
ACCORDANCE WITH THE REQUIREMENTS OF THE TEXAS OPEN
MEETING ACT; REPEALING ANY PRIOR RESOLUTIONS
INCONSISTENT WITH THIS ORDINANCE AND REQUIRING DELIVERY
OF THIS ORDINANCE TO THE COMPANY AND LEGAL COUNSEL
WHEREAS, the City of Plainview, Texas ("City") has exclusive original
jurisdiction as a regulatory authority over Southwestern Public Service Company ("SPS"
or "Company") rates, operations, and services within the City; and
WHEREAS, the City is also an electric utility customer of SPS, and has an
interest in SPS's rates and charges; and
WHEREAS, SPS filed a Statement of Intent with the City on or about August 21,
2017 to increase its base revenue requirement by approximately $80.9 million on a
Texas retail jurisdictional basis, which includes $14.6 million currently being recovered
through SPS's Transmission Cost Recovery Factor ("TCRF"), for a net base rate
increase of $66.3 million, which equates to a 12.3% increase in revenues; and
WHEREAS, SPS filed rebuttal testimony in the pending proceeding at the Public
Utility Commission of Texas revising its requested revenue increase to a $32 million
increase with a net increase of $17.4 million after accounting for the inclusion of $14.6
million in revenues currently being collected through SPS's TCRF; and
WHEREAS, the City took action to suspend the effective date and to coordinate
a response to SPS' filing with other similarly situated municipalities (such participating
cities are referred to herein as the Alliance of Xcel Municipalities ("AXM")); and
WHEREAS, the City took action on or before September 25, 2017 to suspend the
effective date; and
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WHEREAS, one of AXM's goals is to minimize rate -case expenses to the extent
reasonable, that otherwise would result from lengthy, contested rate -case proceedings
before the Public Utility Commission of Texas ("PUCT") and through the appellate
process in the courts for the pending rate case; and
WHEREAS, AXM authorized its attorneys and experts to formulate and review
reasonable settlement positions to resolve SPS' pending request to increase rates; and
WHEREAS, AXM's attorneys met numerous times with the Company to
negotiate a Settlement Agreement resolving the issues raised by the Company's
Statement of Intent filing; and
WHEREAS, AXM's attorneys and experts have evaluated what a likely outcome
from a fully -litigated proceeding would be and are of the opinion that the parties'
agreement for no increase in revenues as noted in the negotiated Settlement
Agreement attached as "Exhibit A," compares favorably with a likely outcome from a
fully -litigated proceeding; and
WHEREAS, after extensive review and analysis, AXM's attorneys and experts
found that no increase in revenues instead of the $66.3 million net base revenue
increase initially proposed, and later revised to a net $17.4 million increase, by SPS is
reasonable; and
WHEREAS, AXM's attorneys and experts and AXM's Steering Committee, based
on the advice of its attorneys and experts, recommend that AXM's members approve
the negotiated Settlement Agreement; and
WHEREAS, under the Public Utility Regulatory Act, the City has a right to
reimbursement of its reasonable rate -case expenses and SPS has an obligation to
reimburse the City's reasonable rate -case expenses; and
WHEREAS, the Settlement Agreement is in the public interest;
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF PLAINVIEW, TEXAS
HEREBY ORDAINS THAT:
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Section 1. The findings set out in the preamble are in all things approved and
incorporated herein as if fully set forth.
Section 2. The City Council finds that the Settlement Agreement, which is attached
hereto as EXHIBIT A and incorporated herein, is in the public interest and is hereby
endorsed in all respects, including requiring SPS to reimburse the AXM cities' rate case
expenses.
Section 3: The City Council hereby directs SPS to reimburse the AXM cities the rate
case expenses incurred directly or indirectly related to SPS' statement of intent to
increase rates.
Section 3. SPS' existing rates, which will not change as a result of the Settlement
Agreement, and are just and reasonable.
Section 4. To the extent any resolution or ordinance previously adopted by the
Council is inconsistent with this Ordinance, it is hereby repealed.
Section 5. The meeting at which this Ordinance was approved was in all things
conducted in strict compliance with the Texas Open Meetings Act, Texas Government
Code, Chapter 551.
Section 6. If any one or more sections or clauses of this Ordinance is adjudged to be
unconstitutional or invalid, such judgment shall not affect, impair or invalidate the
remaining provision of this Ordinance and the remaining provisions of the Ordinance
shall be interpreted as if the offending section or clause never existed.
Section 7. This Ordinance shall become effective from and after its passage.
Section 8. The City Secretary or other appropriate city official as a courtesy, shall
provide SPS a copy of this Ordinance by sending a copy of the Ordinance to William A.
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Grant, Regional Vice -President, Regulatory and Strategic Planning, Southwestern
Public Service Company, 790 S. Buchanan Street, Amarillo, Texas 79101 and AXM
shall be notified by sending a copy of this Ordinance to Mr. Alfred R. Herrera, Herrera
Law & Associates, PLLC, 816 Congress Ave., Suite 950, Austin, Texas 78701.
PASSED AND APPROVED on first reading this 14th day of August, 2018.
PASSED AND APPROVED on second reading this 28th day of August, 2018. •
C
Wendell Dunlap, Mayor
SL
Belinda Hinojosa, Cit -cretary
Ordinance No. 18-3678 Page 4 of 4
Exhibit "A"
SOAH DOCKET NO. 473-17-5771
PUC DOCKET NO. 47527
APPLICATION OF SOUTHWESTERN § BEFORE THE STATE OFFICE
PUBLIC SERVICE COMPANY FOR § OF
AUTHORITY TO CHANGE RATES § ADMINISTRATIVE HEARINGS
UNOPPOSED STIPULATION
(Filename: 47527 Unopposed Stipulation.docx; Total Pages: 26)
Table of Contents
UNOPPOSED STIPULATION 3
1. Revenue Requirement — No Change to Current Base Rates and the TCRF is Not Set to
Zero 4
2. Resolution of Revenue Requirement Issues 5
3. Rate Case Expenses 10
4. Timing of SPS's Next Base Rate Case 10
5. TCRF, Distribution Cost Recovery Factor ("DCRF"), and Purchased Power Cost
Recovery Factor ("PCRF") Filings 10
6. Renewable Energy Credits ("RECs") 10
7. Schedule S Waiver 10
8. Transition Plan to Eliminate the Residential Space Heating ("RSH") Rate 11
9. Abandonment of Docket No. 43695 Appeal 12
10. Cash Working Capital for Earnings Monitoring Reports 12
11. Classes for SPS Energy Efficiency Cost Recovery Factor ("EECRF") Filings 12
12. Solar PPAs 13
13; Proposed Order 13
14. Obligation to Support this Stipulation 13
15. Effect of Stipulation in this Proceeding 13
16. Effect of Stipulation in Other Regulatory Proceedings 14
17. Entire Agreement 15
18. Multiple Counterparts 15
CERTIFICATE OF SERVICE 26
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EXHIBIT
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ATTACHMENTS:
Attachment A — Tolk Depreciation Rates 27
Attachment B — Pension and OPEB Expense Tracker Baseline and
Amortization 30
Attachment C — Proposed Final Order 32
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SOAH DOCKET NO. 473-17-5771
PUC DOCKET NO. 47527
APPLICATION OF SOUTHWESTERN § BEFORE THE STATE OFFICE
PUBLIC SERVICE COMPANY FOR § OF
AUTHORITY TO CHANGE RATES § ADMINISTRATIVE HEARINGS
435
UNOPPOSED STIPULATION
The Signatories to this Unopposed Stipulation ("Stipulation"), which is dated as of June 29,
2018, are the following:
• Staff ("Staff") of the Public Utility Commission of Texas ("Commission");
• Southwestern Public Service Company ("SPS");
• International Brotherhood of Electrical Workers Local Union 602 ("IBEW"
• Texas Industrial Energy Consumers ("TIEC");
• Texas Cotton Ginners' Association ("TCGA");
• Alliance of Xcel Municipalities ("AXM");
• Office of Public Utility Counsel ("OPUC");
• United States Department of Energy ("DOE");
• Amarillo Recycling Co., Inc.;
• Wal-Mart Stores Texas, LLC, and Sam's East, Inc. ("Wal-Mart");
• Sierra Club; and
• Canadian River Municipal Water Authority ("CRMWA").
Golden Spread Electric Cooperative ("GSEC") does not join this Stipulation but does not
oppose it. 1
The parties to this Stipulation shall be referred to individually either as a Signatory or by
the acronym assigned above, and collectively as the Signatories. The Signatories submit this
I In addition to the parties listed above, there is one additional intervenor, Mr. Nathan Porterfield, an
individual residential customer. SPS has attempted to contact Mr. Porterfield, and has provided him drafts of the
Stipulation, but has been unable to confer with hien regarding this Stipulation.
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Stipulation to the Commission as representing a just and reasonable disposition of the issues
related to this docket consistent with the public interest. The Signatories request approval of this
Stipulation and entry of findings of fact and conclusions of law consistent with that approval.
On August 21, 2017, in accordance with Chapter 36 of the Public Utility Regulatory Act,
Tex. Util. Code Ann. §§ 11.001-58.303 (West 2016), 59.101-66.017 (West 2007 & Supp. 2016)
("PURA"), SPS filed its application with the Commission seeking authority to revise its base
rates. SPS's application used a test year of April 1, 2016 through March 31, 2017 ("Test Year"),
with an update period of April 1, 2017 through June 30, 20I7 ("Update Period"), as authorized
by PURA § 36.112 and 16 Tex. Admin. Code ("TAC") § 25.246. SPS filed its case update on
October 5, 2017, including the actual information for the Update Period. SPS's application, as
later modified by update, supplemental, and rebuttal testimony, requested, among other things,
that the Commission authorize a $32,009,475 increase in SPS's Texas retail jurisdictional base
rate revenues. In conjunction with the base rate increase, SPS's transmission cost recovery
factor approved in Docket No. 468772 ($14,373,803) would be set to zero. The final base rates
set in this proceeding relate back to January 23, 2018 in accordance with PURA § 36.211. Under
State Office of Administrative Hearings Order No. 6, the current statutory deadline is November
2, 2018.
By this Stipulation, the Signatories resolve all of the issues among them related to SPS's
application in this docket, and agree as follows:3
Revenue Requirement — No Change to Current Base Rates and the TCRF is Not
Set to Zero
(A) There is a change of zero dollars in SPS's net revenues by maintaining the base
rates set in Docket No. 455244 and the TCRF approved in Docket No. 46877. The
2 Application of Southwestern Public Service Company for Approval of Transmission Cost Recovery
Factor, Docket No. 46877 Order (Jun, 29, 2017).
J The issue of rate case expenses was severed into Docket No. 47588. The DOE Pantex billing dispute
issues were severed into Docket. No. 48440.
4 Application of Southwestern Public Service Company for Authority to Change Rates, Docket No. 45524,
Order (Jan. 26, 2017).
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rate tariffs will remain the same as those currently on file and approved by the
Commission, or the local regulatory authorities, as the case may be.
(B) (i) SPS is allowed to recoup the TCRF rider revenue it would have billed
("revenue to be recouped") had it not ceased billing the TCRF rider for
usage during the period January 23, 2018 through June 10, 2018
("recoupment period"). SPS will determine the revenue to be recouped by
rebilling customer usage for the recoupment period. By November 30,
2018, SPS will file an application requesting approval of the specific
TCRF recoupment rider charges.
(ii) In calculating the revenue to be recouped, SPS will include the revenue
that would have been billed to all service schedules subject to the TCRF
established in Docket No. 46877, but the TCRF recoupment rider will be
designed so that certain service schedules ("exempt service schedules")
will be charged zero dollars under the TCRF recoupment rider and the
revenue that would have been recouped from the exempt service schedules
will instead be collected from the other service schedules that are subject
to the TCRF established in Docket No. 46877 ("paying service
schedules"). The paying service schedules will be responsible for the
revenue that otherwise would be recouped from the exempt service
schedules on an equal percentage base rate (including TCRF) basis using
Updated Test Year billing determinants. The exempt service schedules
are: Secondary General Service; Primary General Service; Large School;
and Small Municipal and School Service.
2. Resolution of Revenue Requirement Issues
This Stipulation is a black box settlement for all revenue requirement issues concerning
Texas retail rates except for the following specifications:
(A) Depreciation Expense.
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There will be no change in SPS's existing Commission -approved
depreciation rates, except as provided in Section 2(A)(ii),
The Signatories agree that the Commission should approve 50% of SPS's
proposed change in depreciation rates for the Tolk Generating Station
Units 1 and 2 based upon a retirement date of 2032. The resulting Tolk
depreciation rates are provided in Attachment A to this Stipulation. All
Signatories reserve their rights regarding Tolk retirement dates in all
future proceedings. SPS agrees to update its Tolk Station economic life
analysis and include it in SPS's next Texas retail base rate case
application.
(B) Financial Items.
(i) The Signatories acknowledge that SPS has explained that in light of the
treatment of Tolk depreciation rates in Section 2(A)(ii) and SPS's
concerns with the impact of the Tax Cuts and Jobs Act, SPS intends to
manage its Texas retail financing operations to a 57% equity capitalization
ratio.
(ii) The Signatories acknowledge that SPS has stated its concerns that in light
of the credit quality, cash flow, and financial metrics concerns it has
raised, SPS asserts that an equity capitalization ratio of Less than 57% (in
light of' Section 2(A)(ii)) likely would have adverse cost consequences for
SPS and its customers.
(iii) SPS acknowledges that the Signatories disagree with SPS's concerns and
assertions that are described in Section 2(B)(ii).
(iv) SPS agrees that the capital structure for ratemaking purposes will be an
issue in its next base rate case and that this Stipulation creates no
presumption about the appropriate capital structure for ratemaking
purposes in future proceedings. All Signatories reserve their rights
regarding an appropriate equity capitalization ratio in SPS's next base rate
case.
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(v) For Allowance for Funds Used During Construction purposes only, SPS
will use a 9.5% ROE in conjunction with using its actual capital structure
per the instructions in the Uniform System of Accounts.
(C) Tax Cuts and Jobs Act ("TCJA").
(i) This Stipulation incorporates the full effects of the TCJA. The relate -back
date in this rate case is January 23, 2018, which is two days before the
Commission issued its order in Project No. 47945.
(a) With regard to the reduction in the corporate federal income tax
rate from 35% to 21% and the corresponding change to SPS's
income tax expense, both SPS's rebuttal cost of service and Staff's
cost of service in its direct case calculated SPS's federal income
tax expense using the 21% tax rate. Thus, the disposition of the
regulatory liability the Commission directed SPS to establish in
Project No. 47945 regarding the reduction in the corporate tax rate
is resolved through the base rates established under this settlement,
and SPS has no refund or bill credit obligation regarding that
regulatory liability.
(b) With regard to the excess Accumulated Deferred Federal Income
Taxes ("ADFIT") and Net Operating Loss ("NOL") -related
balances resulting from the TCJA, both SPS's rebuttal cost of
service and Staff's cost of service in its direct case reflected
amortizations of excess ADFIT balances for protected and
unprotected plant items, excess ADFIT balances for non -plant
items, and excess NOL -related balances resulting from the TCJA
as restated for the June 30, 2017 Updated Test Year. SPS
acknowledges that it is obligated to continue to unwind its excess
ADFIT and NOL -related balances resulting from the change in tax
rates under the TCJA, and that continued unwinding will be
reflected in the calculation of SPS's cost of service in future base
rate cases along with the calculation of all other components of the
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cost of service. Thus, for the Updated Test Year ending June 30,
2017, the disposition of the regulatory liability the Commission
directed SPS to establish in Project No. 47945 regarding the excess
ADFIT and NOL -related balances is resolved through the base
rates established under this settlement and SPS's obligation to
continue unwinding those balances in future rate cases.
(1) In future rate cases, SPS will continue to unwind the excess
ADFIT balances associated with protected plant items
based on the Average Rate Assumption Method
("ARAM"), which is the amortization period SPS used to
calculate the unwinding of this category of excess ADFIT
in its rebuttal cost of service, and which Staff also used in
its cost of service.
(2) In the current rate case, SPS will unwind the excess ADFIT
balances associated with unprotected plant items based on
the ARAM. Signatories reserve the right to address the
appropriate amortization of the remaining balances of
ADFIT for unprotected plant items in SPS's next rate case.
(3) In future rate cases, SPS will continue to unwind the excess
ADFIT balances associated with non -plant items using a
five-year amortization period, which is the amortization
period SPS used to calculate the unwinding of this category
of excess ADFIT in its rebuttal cost of service, and which
Staff also used in its cost of service.
(4) In future rate cases, SPS will continue to unwind the excess
NOL -related balances over a 44 -year period, the average
ARAM period, which is the amortization period SPS used
to calculate the unwinding of the excess NOL -related
balances in its rebuttal cost of service, and which Staff also
used in its cost of service.
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(5)
In future rate cases, SPS will address its excess ADFIT
balances, and the unwinding of those balances, associated
with protected and unprotected plant items, non -plant
items, and NOL -related balances that may have accrued
from the end of the Updated Test Year in this case through
December 31, 2017.
(D) Capital Additions. The capital additions that SPS closed to plant in service during
the period of January 1, 2016 through June 30, 2017 that are included in SPS's
Updated Test Year rate base are reasonable and necessary.
(E) Pension and Other Post -Employment Benefit ("OPEB") Expense Tracker.
(i)
The pension and OPER expense tracker balance as of June 30, 2017 is set
forth in Attachment B to this Stipulation. This balance will be amortized
over a 24 -month period starting February 1, 2018. Any remaining
unamortized amounts can be included in a subsequent base rate case filing
and are deemed reasonable and necessary,
The baseline for the pension and OPEB expense tracker as of July 1, 2017
is set forth in Attachment B to this Stipulation.
(F) Margins on Off -System Energy Sales. For calculating eligible fuel expense from
the date of the final order in this case going forward until the earlier of the date of
the final order in SPS's next fuel reconciliation date or the relate -back date in
SPS's next base rate case, SPS will credit Texas retail customers with 100% of
the Texas retail margins on generation book off -system energy sales.
(G) Demand and Energy Loss Factors. The Signatories agree that SPS's line loss
study presented in this case is approved and the resulting demand and energy loss
factors are approved. The Signatories agree that the effective date of the new
demand and energy loss factors is February 1, 2018.
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3. Rate Case Expenses
The rate case expenses incurred for this docket will remain the subject of Docket No.
47588, but SPS agrees that in Docket No. 47588 it will cap its request for rate case expenses
associated with Docket No. 47527 to $1.45 million related to SPS's rate case expenses and
AXM's rate case expenses and will nonetheless reimburse AXM's rate case expenses. The cap
in Docket No. 47588 applies only to rate case expenses associated with Docket No. 47527 and
does not apply to SPS's request for the rate case expenses, including AXM's, for Docket Nos.
46025 (fuel reconciliation) and 46877 (TCRF).
4. Timing of SPS's Next Base Rate Case
SPS confirms that it will file its next base rate case no later than December 31, 2019.
5. TCRF, Distribution Cost Recovery Factor ("DCRF"), and Purchased Power Cost
Recovery Factor ("PCRF") Filings
SPS agrees it will not file for a TCRF, DCRF, or PCRF until after the Commission issues
its final order in the next SPS rate case.
6. Renewable Energy Credits ("RECs")
(A) Bundled Texas -generated RECs will be priced at $0.27 starting on June 1, 2018;
and
(B) The Texas Commission will establish the value for Texas -generated bundled
RECs and the New Mexico Public Regulation Commission will establish the
value for New Mexico -generated bundled RECs.
7. Schedule S Waiver
For SPS's next base rate case, consistent with Section D of the Unanimous Stipulation in
Docket No. 46328 (the rate case expenses case for Docket No. 45524), the Signatories agree to
support or not oppose a:request by SPS to waive the requirement to file Schedule S of the current
rate filing package, provided that the test year (or update period) for the next base rate case ends
on the last day of a fiscal quarter.
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8. Transition Plan to Eliminate the Residential Space Heating ("RSH") Rate
(A) SPS will propose a Residential Service ("RS") rate design in its next base rate
case that eliminates the RSH Rider consistent with the RS rate design proposed in
this rate case. The new rate design for the Residential class will be designed to
moderate the effect on RSH customers of eliminating the RSH option. The new
rate design is intended to be revised or eliminated in future rate proceedings as the
need to moderate the effect of the elimination of the RSH Rider on RSH
customers diminishes. SPS agrees to make available upon request cost and billing
determinant information necessary to calculate RS rates based on initial
consumption band alternatives of 400 kilowatt-hours ("kWh"), 500 kWh, 600
kWh, 700 kWh, 800 kWh, 900 kWh, 1,000 kWh, 1,100 kWh, and 1,200 kWh.
(B) If, as in Docket No. 45524, further mitigation of rate impacts for RSH customers
is deemed necessary, SPS may propose a temporary rider designed to provide a
credit per kWh to all Residential customers for above-average residential
consumption during the winter months as defined in the current RS rate tariff
(billing months of October through May), to be phased out over a period of time.
The cost of the credit will be recovered through an increase to the RS energy
charge throughout the year, with the increase to be phased out concurrent with the
phase-out of the credit and the phase-out of the RSH rider, in a manner designed
to be revenue -neutral for SPS. The temporary rider will end at the conclusion of
the summer months as defined in the current RS rate tariff (billing months of June
through September) in the year after the effective date of the new rates set in
SPS's next base rate case, unless SPS, Staff, and OPUC jointly recommend a
different ending date and the Commission approves that date. Rate changes under
the temporary rider and the elimination of the rider are not to occur during the
winter months (as defined in the current RS rate tariff). The target end date for
the temporary rider is the end of the summer period concluding September 30,
2020.
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(C) SPS agrees to continue to implement the plan developed in cooperation with Staff
and OPUC to: (1) develop a plan to inform RSH customers that the RSH option is
ending and to communicate to RSH customers the value of the Residential Time
of Use Rider; and (2) to market the Residential Time of Use Rider in general.
SPS agrees to implement the plans prior to the conclusion of its next base rate
case.
(D) Beginning with SPS's next base rate case, any cap on the number of customers
joining the residential time -of -use ("TOU") rate plans will not include a limit on
RSH customers seeking to participate in the TOU rate plans.
9. Abandonment of Docket No. 43695 Appeal
SPS agrees to abandon its appeal from Docket No. 43695.
10. Cash Working Capital for Earnings Monitoring Reports
For preparation of SPS's Earnings Monitoring Reports for reporting years 2018 and
2019, SPS's total company Cash Working Capital is $-16,753,708 and SPS's Texas retail
amount is $-9,134,277.
11. Classes for SPS Energy Efficiency Cost Recovery Factor ("EECRF") Filings
For all SPS EECRF cases filed before the final order in SPS's next base rate case
becomes final, as defined under Tex. Govt. Code § 2001.144, the classes approved in Docket No.
459165 will: (a) continue to be the classes for purposes of SPS's EECRF cases; and (b) be
considered the rate classes in SPS's "most recent base -rate proceeding" under 16 Tex. Admin.
Code § 25.181(c)(49), Those classes are:
Residential Service;
Small General Service;
Secondary General Service;
5 Application of Southwestern Public Service Company to Adjust Its Energy Efficiency Cost Recovery
Factor, Docket No. 45916, Order at Finding of Fact No. 23 (Sept. 23, 2016).
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Primary General Service;
Small Municipal and School Service;
Large Municipal Service; and
Large School Service.
12. Solar PPAs
The Signatories agree that SPS's request for a finding that it acted prudently in entering
into the purchased power agreements with NextEra Energy Resources Acquisition, LLC for the
Roswell Solar and Chaves County Solar facilities (collectively, "Solar PPAs") should be
deferred until SPS's next fuel reconciliation proceeding. The Signatories support applying the
prudence or imprudence determination in the next fuel reconciliation proceeding to the entire
period in which the Solar PPAs are in effect. A finding of the prudence of entering into the Solar
PPAs would not be dispositive as to the prudence of SPS's day-to-day operations or
administration under the contracts. The Signatories reserve all rights related to the Solar PPAs in
that proceeding, including whether SPS has met its burden of proof to demonstrate that it was
prudent to enter into the Solar PPAs.
13. Proposed Order
The Signatories agree to request entry of the proposed order shown on Attachment C to
this Stipulation.
14. Obligation to Support this Stipulation
The Signatories agree that they will support this Stipulation before the Commission.
15. Effect of Stipulation in this Proceeding
(A) There are no third -party beneficiaries of this Stipulation. This Stipulation
resolves issues only with respect to the Texas retail jurisdiction and shall not be
binding on or have any effect on proceedings in other jurisdictions. Signatories
are not agreeing to any methodology or theory that may support or underlie any of
the dollar amounts, rates in tariffs, depreciation rates, dollar balances, or other
monetary or numerical values set out in, or attached to, this Stipulation.
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(B) This Stipulation has been drafted by all the Signatories and is the result of
negotiation, compromise, settlement, and accommodation. The Signatories agree
that this settlement is in the public interest. The terms and conditions in this
Stipulation are intended to work in concert with each other as an integrated whole
for the purposes of an outcome in this docket that is in the public interest and that
will result in just and reasonable rates. Thus, the various provisions of this
Stipulation are not severable. None of the provisions of this Stipulation shall
become fully operative unless the Commission shall have entered a final order
consistent with this Stipulation. If the Commission does not issue a final order
consistent with the terms of this Stipulation, each Signatory has the right to
withdraw from this Stipulation, to submit testimony, and to obtain a hearing and
advocate any position it deems appropriate with respect to any issue in this
Stipulation.
16. Effect of Stipulation in Other Regulatory Proceedings
(A) This Stipulation is binding on each of the Signatories only for the purpose of
settling the issues as set forth herein in this jurisdiction only and for no other
purposes. The matters resolved herein are resolved on the basis of a compromise
and settlement. Except to the extent that this Stipulation expressly governs a
Signatory's rights and obligations for future periods, this Stipulation shall not be
binding or precedential on a Signatory outside of this proceeding or a proceeding
to enforce the terms of this Stipulation. Each Signatory acknowledges that a
Signatory's support of the matters contained in this Stipulation may differ from
the position taken or testimony presented by it in other dockets or other
jurisdictions. To the extent that there is a difference, a Signatory does not waive
its position in any of those other dockets or jurisdictions, Because this is a
stipulated resolution, no Signatory is under any obligation to take the same
positions as set out in this Stipulation in other dockets or jurisdictions, regardless
of whether other dockets present the same or a different set of circumstances,
except as otherwise may be explicitly provided by this Stipulation. Agreement by
SOAH Docket No. 473-17-5771 Unopposed Stipulation
PUC Docket No. 47527
-14-
14
the Signatories to any provision in this Stipulation will not be used against any
Signatory in any future proceeding with respect to different positions that may be
taken by that Signatory. The Signatories agree that in the event of a violation of
the immediately preceding sentence, a violating Signatory will be given notice of
violation in writing, which notice can be provided by e-mail, and a reasonable
opportunity to cure.
(B) The provisions of this Stipulation are intended to relate to only the specific
matters referred to herein. By agreeing to this Stipulation, no Signatory waives
any claim it may otherwise have with respect to issues not expressly provided for
herein. The Signatories further understand and agree that this Stipulation
represents a negotiated settlement of all remaining issues in this proceeding:
(C) This Stipulation resolves the stated issues in the Texas retail jurisdiction only, and
this Stipulation does not resolve any claims, issues or proceedings pending in or
pertaining to other jurisdictions.
17. Entire Agreement
This Stipulation contains the entire understanding and agreement of the Signatories, and
it supersedes all other written and oral exchanges and negotiations among them or their
representatives with respect to the subjects contained in the Stipulation.
18. Multiple Counterparts
Each copy of this Stipulation may not bear the signatures of all the Signatories but will be
deemed fully executed if all copies together bear the signatures of all Signatories.
Fully and duly authorized representatives of the Signatories have signed this Stipulation
as of the date first set forth above.
[signature pages follow]
SOAH Docket No. 473-17-5771
PUC Docket No. 47527
-15-
Unopposed Stipulation
15
447
448
STAFF OF THE PUBLIC UTILITY
COMMISSION OF TEXAS
By: 4 ---
Richard Nemer
Hunter Burkhalter
Eleanor D'Ambrosio
Attorneys of Record
SOUTHWESTERN PUBLIC SERVICE
COMPANY
By:
Stephen Fogel
Ron H. Moss
Attorneys of Record
AMARILLO RECYCLING COMPANY, INC. ALLIANCE OF XCEL MUNICIPALITIES
13y: --- — -- Rick L. Russwunn
Moore, Lewis, Russwunn, PC
Attorney of Record
CANADIAN RIVER MUNICIPAL WATER
AUTHORITY
By:
R. Michael Anderson
Joshua D. Katz
Bickerstaff, Heath, Delgado, Acosta, LLP
Attorneys of Record
OFFICE OF PUBLIC UTILITY COUNSEL
By:
Sara J. Ferris
Cassandra Quinn
Christiaan Siano
Attorneys of Record
.SO.II•l Docket No. 473-17-577/
P!!C Docket No. 47527
By:
Alfred R. Herrera
Brennan Foley
Herrera Law & Associates, PLLC
Attorneys of Record
INTERNATIONAL BROTHERHOOD OF
ELECTRICAL WORKERS LOCAL UNION
602
13y:
Jamie L. Mauldin
Thomas L. Brocato
Lloyd Gosselink Rochelle & Townsend, PC
Attorneys of Record
SIERRA CLUB
By:
Joshua Smith
Matthew E. Miller
James Z. Brazell
Attorneys of Record
-/6
Unopposed Stipulation
16
STAFF OF THE PUBLIC UTILITY SOUTHWESTERN PUBLIC SERVICE
COMPANY
COMMISSION OF TEXAS
By:
Richard Nemer
Hunter Burkhalter
Eleanor D'Ambrosio
Attorneys of Record
By:
Stephen Fogel
Ron H. Moss
Attorneys of Record
AMARILLO RECYCLING COMPANY, INC. ALLIANCE OF XCEL MUNICIPALITIES
By:
Rick L. Russwurm
Moore, Lewis, Russwurm, PC
Attorney of Record
By:
Alfred R. Herrera
Brennan Foley
Herrera Law & Associates, PLLC
Attorneys of Record
CANADIAN RIVER MUNICIPAL WATER INTERNATIONAL BROTHERHOOD OF
AUTHORITY ELECTRICAL WORKERS LOCAL UNION
602
By:
R. Michael Anderson
Joshua D. Katz
Bickerstaff, Heath, Delgado, Acosta, LLP
Attorneys of Record
OFFICE OF PUBLIC UTILITY COUNSEL
By:
Sara J. Ferris
Cassandra Quinn
Christiaan Siano
Attorneys of Record
By:
Jamie L. Mauldin
Thomas L. Brocato
Lloyd Gosselink Rochelle & Townsend, PC
Attorneys of Record
SIERRA CLUB
By:
Joshua Smith
Matthew E. Miller
Janes Z, Brazell
Attorneys of Record
SOAHDocket No. 473-17-5771
PUC Docker No. 47527
-16-
Unopposed Stipulation
I6a
449
450
I'THE PUBLIC UTILITY SOUTHWESTERN PUBLIC SERVICE
SION OF TEXAS C'ONIPANY
Ily: 4.
.1: •t:rtl Nemcr
•ra I3tu•khalter
:n:ur 1)'And.aosio
.•.::eys of Record
Stephen Fogel
Icon II. tVioss
Attorneys oI' Record
t\MAIUIJ.0 kliC'YC'1.IN(; COMPANY, INC. AL.I.IAN(.'I.i or XC.7!1., MUNICIPALITIES
y:Ity:
,::1 I.. Rns5 \' R'Ii Allred it, Herrera
,•,,',:•;, Lewis. Russwurni, PC' Brennan Foley
,,,•iey of Record I lerrcra Law & Associates, PLLC
Attorneys of Record
. AN RIVER MUNI('II'AL, WATER
,1;ITY
INI'ERNA'I'IONAI. 13ROTI1UR1-1OO1) OF
ELECTRICAL C TRICAL WOIRKERS LOCAL UNION
(d l?
1.1y: ___ _ -- - .. I$y:
,•,_clatel Anderson ,Itunio 1.. Mauldin
.,:.a D. K;ilz 'I'hontas 1.. IilUeaLo
- •,::; •rstair' Ilu1I.h, L)cagado, /\tush, 1.1 •P Lloyd (;ossa:Iink 1toohclle &I'ownsui(1, PC.'
,: ,. icys of Record Attorneys of Record
)1I'lll3f.EC' tIi II.fl'Y (:OtiNsisl. SII?RRA (`I.UR
Ity: Rv.
):r•; I7errls Joshua Smith
, r.:x.ndra Quinn tvluIlhew E. IVIiiler
.:•,:•iaan Siano .lama::; Z. Brazell
toys of Record Attorney); of Itccnrd
• • ,:r: „'f Mk .173-17--3771 Unu/,pn•ced Silpnlarlun
No, -17531
/ ()
17
STAFF OF THE PUBLIC UTILITY SOUTHWESTERN PUBLIC SERVICE
COMMISSION OF TEXAS
By:
Richard Nemer
Hunter Burkhalter
Eleanor D'Ambrosio
Attorneys of Record
COMPANY
By:
Stephen Fogel
Ron H. Moss
Attorneys of Record
AMARILLO RECYCLING COMPANY, INC. ALLIANCE OF XCEL MUNICIPALITIES
Bv:
Rick L. Russwurm
Moore, Lewis, Russwunn, PC
Attorney of Record
By:
Alfred R. Herrera
Brennan Foley
Herrera Law & Associates, PLLC
Attorneys of Record
CANADIAN RIVER MUNICIPAL WATER INTERNATIONAL BROTHERHOOD OF
AUTHORITY ELECTRICAL WORKERS LOCAL UNION
602
By:
R. Michael Anderson
Joshua D. Katz
Bickerstaff, Heath, Delgado, Acosta, LLP
Attorneys of Record
OFFICE OF PUBLIC UTILITY COUNSEL
By:
Sara J. Ferris
Cassandra Quinn
Christiaan Siano
Attorneys of Record
y:
Jamie L. Mauldin
Thomas L. Brocato
Lloyd Gosselink Rochelle & Townsend, PC
Attorneys of Record
SIERRA CLUB
By:
Joshua Smith
Matthew E. Miller
James Z. Brazell
Attorneys of Record
SOAH Docket No. 473-17-5771 Unopposed Stipulation
PUC Docket No. 47527
-16-
18
451
452
STAFF OF THE PUBLIC UTILITY SOUTHWESTERN PUBLIC SERVICE
COMMISSION OF TEXAS
By:
Richard Nemer
Hunter Burkhalter
Eleanor D'Ambrosio
Attorneys of Record
COMPANY
By:
Stephen Fogel
Ron I I. Moss
Attorneys of Record
AMARILLO RECYCLING COMPANY, INC. ALLIANCE OF XCEL MUNICIPALITIES
By:
Rick L. Russwurm
Moore; Lewis, Russwurm, PC
Attorney of Record
By:
Alfred R. Herrera
Brennan Foley
Herrera Law & Associates, PLLC
Attorneys of Record
CANADIAN RIVER MUNICIPAL WATER INTERNATIONAL BROTHERHOOD OF
AUTHORITY ELECTRICAL WORKERS LOCAL UNION
602
By:
R. Michael Anderson
Joshua. D. Katz
Bickerstaff, Heath, Delgado, Acosta, LLP
Attorneys of Record
OFFICE OF PUBLIC UTILITY COUNSEL
By:
Sara J. Ferris
Cassandra Quinn
Christiaan Siano
Attorneys of Record
Jami L. auldin
Thon Brocato
Lloyd Gosselink Rochelle & Townsend, PC
Attorneys of Record
SIERRA CLUB
By:
Joshua Smith
Matthew E. Miller
James Z. Brazell
Attorneys of Record
SOAK K Docket No. 473-17-5771 Unopposed Stipulation
PUC Docket No. 47527
-J6-
19
STAFF OF THE PUBLIC UTILITY
COMMISSION OF TEXAS
By:
Richard Nemer
Hunter Burkhalter
Eleanor D'Ambrosio
Attorneys of Record
SOUTHWESTERN PUBLIC SERVICE
COMPANY
By:
Stephen Fogel
Ron H. Moss
Attorneys of Record
AMARILLO RECYCLING COMPANY, INC. ALLIANCE OF XCEL MUNICIPALITIES
By:
Rick L. Russwurm
Moore, Lewis, Russwurm, PC
Attorney of Record
By:
Alfred R. Herrera
Brennan Foley
Herrera Law & Associates, PLLC
Attorneys of Record
CANADIAN RIVER MUNICIPAL WATER INTERNATIONAL BROTHERHOOD OF
AUTHORITY ELECTRICAL WORKERS LOCAL UNION
602
By:
R. Michael Anderson
Joshua D. Katz
Bickerstaff, Heath, Delgado, Acosta, LLP
Attorneys of Record
OFFICE OF PUBLIC UTILITY COUNSEL
By:
Sara J. Ftrris
Cassandra Quinn
Christiaan Siano
Attorneys of Record
By:
Jamie L. Mauldin
Thomas L. Brocato
Lloyd Gosselink Rochelle & Townsend, PC
Attorneys of Record
SIERRA CLUB
By:
Joshua Smith
Matthew E. Miller
SOAR Docket Na 473-17-5771
PUC Docket Na 47527
-16-
Unopposed Stipulation
20
453
454
STAFF OF TRE PUBLIC UTILITY
SOUTHWESTERN PUBLIC SERVICE
COMMISSION OF TEXAS COMPANY ,•- ") iJ
By' - --
Richard Nemer
Hunter Burkhalter
Eleanor D'Ambrosio
Attorneys of Record
By: Stephen Fogel
Ron }L Moss
Attorneys of Record
AMARILLO RECYCLING COMPANY, INC. ALLIANCE OF XCEL MUNICIPAL! CIES
By:. -
Rick L. Russwurm
Moore, Lewis, Russwurm, PC
Attorney of Record
By:
Alfred R. Herrera
Brennan Foley
Herrera Law & Associates, PLLC
Attorneys of Record
CANADIAN RIVER MUNICIPAL WATER INTERNATIONAL BROTHERHOOD OF
AUTHORITY ELECTRICAL WORKERS LOCAL UNION
602
By:
R. Michael Anderson
Joshua D. Katz
Bickerstaff, Heath, Delgado, Acosta, LLP
Attorneys of Record
OFFICE OF PUBLIC UTILITY COUNSEL
By:
SAW J. Ferris
Cassandra Quinn
Christiaan Siano
Attorneys of Record
SOA/( Docker No. 473-17-5771
PUC Docker No. 47527
By. --
Jamie L. Mauldin
Thomas L. Brocato
Lloyd Gosselin! Rochelle & Townsend, PC
Attorneys of Record
SIERRA CLUB
By:
Joshua Sa ith
Matthew Miller
James Z. Br. zell
Attorneys of Record
Unopposed S7ipuluriou
21
TEXAS COTTON GINNERS'
ASSOCIATION
By:
Zach Br
Brady ilton, LLP
Attorney of Record
UNITED STATES DEPARTMENT OF
ENERGY
TEXAS INDUSTRIAL ENERGY
CONSUMERS
By:
Rex D. VanMiddlesworth
Benjamin Hallmark
James Zhu
Attorneys of Record
WAL-MART STORES TEXAS, LLC AND
SAM'S EAST, INC.
By: By:
Rishi Garg
Christopher M. Drake
Mark A. Duffy
Attorneys of Record
Lisa V. Perry
Oram & Houghton, PLLC
Attorney of Record
SON/ Docket No. 473-17-5771
PUC Docket No. 47527
-17-
Unopposed Stipulation
22
455
456
TEXAS COTTON DINNERS' TEXAS INDUSTRIAL ENERGY
ASSOCIATION CONSUMERS
By:
Zach Brady ex VanMiddlesworth
Brady & Hamilton, LLP Benjamin Hallmark
Attorney of Record James Zhu
Attorneys of Record
UNITED STATES DEPARTMENT OF WAL-MART STORES TEXAS, LLC AND
ENERGY SAM'S EAST, INC.
By: By:
Rishi Garg Lisa V. Perry
Christopher M. Drake Oram & Houghton, PLLC
Mark A. Duffy Attorney of Record
Attorneys of Record
SOAH Docket No. 473-17-5771
PUC Docket No. 47527
-17-
Unopposed Stipulation
23
TEXAS COTTON GINNERS' TEXAS INDUSTRIAL ENERGY
ASSOCIATION CONSUMERS
By: By:
Zach Brady Rex D. VanMiddlesworth
Brady & Hamilton, LLP Benjamin Hallmark
Attorney of Record James Zhu
Attorneys of Record
UNITED STATES DEPARTMENT OF WAL-MART STORES TEXAS, LLC AND
SAM'S EAST, INC,
ENERGY
By:
Rishi Garg
Christopher M. Drake
Mark A. Duffy
Attorneys of Record
By:
Lisa V. Perry
Oram & Houghton, PLLC
Attorney of Record
SOAHDocket No. 473-17-5771
PUC Docket No. 47527
-17-
Unopposed Stipulation
24
457
458
TEXAS COTTON GINNERS' TEXAS INDUSTRIAL ENERGY
ASSOCIATION CONSUMERS
By:
Zach Brady
Brady & Hamilton, LLP
Attorney of Record
UNITED STATES DEPARTMENT OF
ENERGY
By:
Rishi Garg
Christopher M. Drake
Mark A. Duffy
Attorneys of Record
By:
Rex D. VanMiddlesworth
Benjamin Hallmark
Janes Zhu
Attorneys of Record
WAL-MART STORES TEXAS, LLC AND
SAM'S EAST, INC.
By:
Lisa V. Perry
Oram & Houghton, PLL
Attorney of Record
SOAH Docket No. 473-17-5771
PUC Docket No. 47527
-17-
Unopposed Stipulation
25
CERTIFICATE OF SERVICE
I certify that on June 29, 2018, a true and correct copy of the foregoing instrument was
served on all parties of record by electronic service, hand delivery, Federal Express, regular first
class mail, certified mail, or facsimile transmissr
Ron oss
SOAR Docket No. 473-17-5771 Unopposed Stipulation
PUC Docket No. 47527
26
26
459
460
Southwestern Public Service Company
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Docket No. 47527 Unopposed Stipulation
Attachment B
Page 1 of 2
DOCKET NO. 47527 STIPULATION
ATTACHMENT B
PENSION AND OPEB EXPENSE TRACKER BASELINE AND AMORTIZATION
GOING -FORWARD PENSION AND OPEB BASELINES
As of January 23, 2018, the Texas retail pension and OPEB baselines were $7,830,475 for
qualified pension and $(206,017) for OPEl3. Those amounts were calculated as follows:
Those baseline amounts, which are assumed to be included in the Docket No. 47527 Stipulation
revenue requirement, will be compared to the actual amounts that SPS incurs for pension and
OPEB expense beginning January 23, 2018.
CURRENT PENSION AND OPEB TRACKER BALANCE
In Docket No: 47527, SPS requested that the total net pension and OPEB deferral amount of
($1,166,775) be amortized over a one year period.3 The ($1,166,775) was made up of two parts,
which are shown in the table below. The unamortized amount of $415,879 assumed the $76,730
monthly amortization agreed to in Docket No. 45524 would continue through January 17, 2018.
Pension and OPEB Deferrals
12 Months Ending 6/30/17
Expenses
Jurisdictional
Allocation Factor2
Texas Retail
Amount
Pension
$13,378,566
58.53%
$7,830,475
OPEB
$(351,985)
58.53%
$(206,017)
Those baseline amounts, which are assumed to be included in the Docket No. 47527 Stipulation
revenue requirement, will be compared to the actual amounts that SPS incurs for pension and
OPEB expense beginning January 23, 2018.
CURRENT PENSION AND OPEB TRACKER BALANCE
In Docket No: 47527, SPS requested that the total net pension and OPEB deferral amount of
($1,166,775) be amortized over a one year period.3 The ($1,166,775) was made up of two parts,
which are shown in the table below. The unamortized amount of $415,879 assumed the $76,730
monthly amortization agreed to in Docket No. 45524 would continue through January 17, 2018.
Pension and OPEB Deferrals
Direct
Testimony
Unamortized Amount: Pension and OPEB
expense deferred from prior cases
$415,879
Pension and OPEB expense deferred from
January I, 2016 to June 30, 2017
(1,582,654)
Total Net Pension and OPEB Deferrals
($1,166,775)
Assumed Docket No. 45524
amortization would continue
through January 17, 2018.
Under Section 2(E) of the Docket No. 47527 Stipulation, the unamortized amount will be set as
of June 30, 2017 and will be amortized over a 24 -month period starting February 1, 2018. The
I Source: SPS Ex.. 39A, Update Testimony of Richard R. Schrubbe at 6.
2 Source: SPS Ex. 44A, Update Testimony of Arthur P. Freitas, Attachment APF -RR -U2 at 8, line 236.
3 Source: SPS Ex. 39, Direct Testimony of Richard R. Schrubbe at 42 and 43.
30
463
464
Docket No. 47527 Unopposed Stipulation
Attachment B
Page 2 of 2
change from January 17, 2018.to June 30, 2017 increases the unamortized balance by $502,459,
which is calculated as follows:
$460,380 ($76,730 x 6 months)
$ 42,079 ($76,730 x 54.84%); 17 of 31 days or 17/31=54.84%
$502,459
As a result of this change, the total net pension and OPEB deferral amount is now ($664,316)
and is shown in the table below.
Pension and OPEB Deferrals
Stipulation
Unamortized Amount: Pension and OPEB
expense deferred from prior cases
$918,338
Pension and OPEB expense deferred from
January 1, 2016 to June 30, 2017
(1,582,654)
Total Net Pension and OPEB Deferrals
($664,316)
Assumes Docket No. 47527
amortization continues
through June 30, 2017.
The ($664,316) is the amount that will be amortized over a 24 -month period starting February 1,
2018. The amortization expense is assumed to be included in the Docket No. 47527 Stipulation
revenue requirement. If the entire amount has not been amortized at the time the rates set in
SPS's next base rate go into effect, the Docket No. 47527 Stipulation [Section 2(E)(i)] provides
that the remaining unamortized amount can be included in a subsequent base rate case and is
deemed reasonable and necessary.
31
SOAR DOCKET NO. 473-17-5771
PUC DOCKET NO. 47527
APPLICATION OF SOUTHWESTERN § BEFORE THE STATE OFFICE
PUBLIC SERVICE COMPANY FOR § OF
AUTHORITY TO CHANGE RATES § ADMINISTRATIVE HEARINGS
465
PROPOSED ORDER
This order addresses the application of Southwestern Public Service Company (SPS) for
authority to change rates. An Unopposed Stipulation (agreement) resolves all of the issues
among the parties in this proceeding. The application, as modified by the agreement and this
Order, is granted for the reasons discussed in this Order.
I. Discussion
A. SPS's Application
On August 21, 2017, SPS filed an application requesting authority to revise its base rates.
SPS's application was filed pursuant to PURA' § 36.112, which allows for the utility's revenue
requirement to be based on information submitted for a test year, updated to include information
that reflects the most current actual or estimated information regarding increases or decreases to
the utility's cost of service.2 In short, this provision allows for the use of an updated test year in
establishing a utility's revenue requirement. Based on the use of an updated test year,3 SPS
requested Commission approval of a Texas retail base rate revenue requirement of $608,816,223,
representing an increase of $69,176,106 over SPS's current rates on a Texas retail basis.
After SPS filed its application in this case, the Tax Cuts and Jobs Act (TCJA) was
enacted into law, which raised questions regarding how the TCJA should be reflected in the rates
approved in this proceeding. Consequently, SPS filed supplemental testimony addressing the
effects of the TCJA on SPS's cost of service and modified certain aspects of its requested relief.
' Public Utility Regulatory Act, Tex. Util. Code Ann. §§ 11.001 — 58.032 (West 2016 & Supp. 2017), §§
59.001 — 66.016 (West 2007 & Supp. 2017) (PURA).
2 PLJRA § 36.112(b).
SPS elected to provide information submitted for a test year but updated to include estimated information for
an update period, which was the three-month period from April 1, 2017 through June 30, 2017. This effectively created
an updated test year consisting of the twelve-month period from July 1, 2016 through June 30, 2017.
PUC Docket No. 47527 Proposed Order
SO,4H Docket No. 473-17-5771 Attachment C to the Unopposed Stipulation
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466
As modified by supplemental testimony and subsequent rebuttal testimony, SPS's requested
relief in this proceeding is approval of a Texas retail base rate revenue requirement of
$573,198,459, would be an increase of $32,009,475 over SPS's current level of Texas retail base
rates, a 5.9% base rate increase. In conjunction with the proposed base rate increase, SPS's
transmission cost recovery factor approved in Docket No. 468774 ($14,373,803) would be set to
zero.
B. The Settlement Agreement
A settlement agreement was filed on June 26, 2018, and was signed by: Commission
Staff (Staff); SPS; -International Brotherhood of Electrical Workers Local Union 602 (IBEW);
Texas Industrial Energy Consumers (TIEC); Texas Cotton Ginners' Association (TCGA);
Alliance of Xcel Municipalities (AXM); Office of Public Utility Counsel (OPUC); United States
Department of Energy (DOE); Amarillo Recycling Co., Inc.; Wal-Mart Stores Texas, LLC, and
Sam's East, Inc. (Wal-Mart); Sierra Club; and Canadian River Municipal Water Authority
(CRMWA). Golden Spread Electric Cooperative, Inc. (GSEC) does not join the Stipulation but
does not oppose it.
The settlement resolves all of the issues related to SPS's application in this docket.5 The
settlement agreement results in a change of zero dollars in SPS's net revenues by maintaining the
base rates set in Docket No. 455246 and the Transmission Cost Recovery Factor (TCRF)
approved in Docket No. 46877.7
The Commission concludes that SPS's application, as modified by the settlement
agreement and this Order, should be granted.
The Commission adopts the following findings of fact and conclusions of law:
II. Findings of Fact
4 Application of Southwestern Public Service Company for Approval of Transmission Cost Recovery
Factor, Docket No. 46877 Order (Jun. 29, 2017).
5 The issue of rate case expenses was severed into Docket No. 47588. The DOE's billing dispute with SPS
relating to the Pantex facility was severed into Docket No. 48440.
6 Application of Southwestern Public Service Company for Authority to Change Rate, Docket No. 45524,
Order (Jan. 26, 2017).
Application of Southwestern Public Service Company for Approval of Transmission Cost Recovery
Factor, Docket No. 46877 Order (Jun. 29, 2017).
PUC Docket No. 47527 Proposed Order
Attachment C to the Unopposed Stipulation
SOAK Docket No. 473-17-5771
- 2-
33
Procedural History
1. SPS is an investor-owned electric utility with a retail service area located in Texas.
2. SPS serves retail and wholesale electric customers in Texas and New Mexico. The New
Mexico Public Regulation Commission regulates SPS's New Mexico retail operations.
The Federal Energy Regulatory Commission regulates SPS's wholesale electric
operations.
3. On August 21, 2017, SPS filed an application requesting authority to change its Texas
retail rates. SPS requested an overall increase in base rate revenues for the Texas retail
jurisdiction of $80,949,614 per year. In conjunction with the proposed base rate increase,
SPS's transmission cost recovery factor approved in Docket No. 46877 ($14,373,803)
would be set to zero. SPS also requested approval of a set of proposed tariff schedules
reflecting the increased rates and other revised terms.
4. SPS's requested an effective date for the new rates and tariff schedules of September 25,
2017. SPS's application stated that, under PURA8 § 36.211, if the Commission suspends
the proposed rates, the final rates set in this case would relate back to January 23, 2018.
5. SPS filed its application with the Commission seeking authority to revise its base rates
based upon an "Updated Test Year" of July 1, 2016 through June 30, 2017, which by the
end of the case would be the product of a historical test year of April 1, 2016 through
March 31, 2017 (Test Year), updated to include actual infonnation for the period from
April 1, 2017 through June 30, 2017 (Update Period), as authorized by PURA § 36.112
and 16 Tex. Admin. Code (TAC) § 25.246.
6. SPS provided notice by publication for four consecutive weeks before the effective date
of the proposed rate change in newspapers having general circulation in each county of
SPS's Texas service territory. SPS also mailed notice of its proposed rate change to all of
its customers. Additionally, SPS timely served notice of its statement of intent to change
rates on all municipalities retaining original jurisdiction over its rates and services.
7. The following parties were granted intervenor status in this docket: Amarillo Recycling
Co., Inc.; AXM; CRMWA; GSEC; IBEW; Nathan Porterfield; OPUC; Sierra Club;
8 PURA is codified at Tex. Util. Code Ann. §§ 11.001-58.303- (West 2016), 59.101-66.017 (West 2007 &
Supp. 2016).
PUC Docket No. 47527
SOAH Docket Na 473-17-5771
- 3 -
Proposed Order
Attachment C to the Unopposed Stipulation
34
467
468
Texas Cotton Ginners' Association; TIEC; DOE; and Wal-Mart. Staff became a party as
a matter of right.
8. All of SPS's timely filed petitions for review of the rate ordinances of the municipalities
exercising original jurisdiction with SPS's service territory were consolidated for
determination in this proceeding.
9. On August 23, 2017, the Commission referred this case to the State Office of
Administrative Hearings (SOAH).
10. On August 24, 2017, the SOAH Administrative Law Judges (ALJs) issued SOAH Order
No. 1, description of application and jurisdiction, suspension of effective date, protective
order, notice of prehearing conference, notice and other procedures.
11. On September 8, 2017, the SOAH ALJs issued SOAH Order No. 2, which set a
procedural schedule for this docket in addition to memorializing the prehearing
conference, granting motions to intervene, severing the rate case expense issues,
addressing notice and sufficiency of application, and revising the effective date. Docket
No. 47588, Review of the Rate Case Expenses Incurred in Docket No. 47527, was
established for the severed rate case expense issues.
12. On September 29, 2017, the Commission issued its preliminary order, identifying a non -
exhaustive list of 53 issues to be addressed in this proceeding.
13. On October 5, 2017, SPS filed its case update, including updated testimony to replace its
estimated information for the Update Period with actual information. SPS's filing also
included its 45 -day case update as required by the Commission's RFP, and reflected that
rate case expenses had been severed from this docket. With this case update, SPS's
requested base rate increase became $69,176,106.
14. On February 2, 2018, SPS filed a request for leave to file supplemental direct testimony
addressing the effects of the TCJA and moved to adopt a proposed revised procedural
schedule.
15. On February 6, 2018, the ALJs held a telephonic prehearing regarding SPS's February
2"d motion.
16. On February 8, 2018, SOAH issued Order No. 6, granting the request for leave to file
supplemental direct testimony, revising the procedural schedule and extending the record
PUC Docket No. 47527 Proposed Order
SOAH Docket Na 473-17-5771 Attachment C to the Unopposed Stipulation
-4-
35
469
close date and the jurisdictional deadline. Under the order, the record close date became
July 19, 2018.
17. On February 16, 2018, SPS filed Supplemental Testimony and RFP Schedules,
addressing the effects of the TCJA. With this supplemental filing, SPS's requested base
rate increase became $37,495,033 million, reflecting a reduction of $31,681,073 to SPS's
requested updated test year revenue requirement increase due to the effects of the TCJA.
18. On April 25, 2018, Intervenors filed direct testimony.
19. On May 2, 2018, Commission Staff filed direct testimony.
20. On May 22, 2018, Intervenors and Commission Staff filed Cross -Rebuttal Testimony.
21. On May 23, 2018, SPS filed rebuttal testimony. In that testimony, SPS reduced its
requested rate increase to $32,009,475 million to incorporate the effects of the TCJA and
to reflect certain corrections, adjustments, and concessions.
22. On May 30, 2018, a prehearing conference was held at which evidence for this docket
was admitted.
23. On June 4, 2018, the prehearing conference and the hearing in this case were postponed
until June 5, 2018 so that the parties could engage in settlement discussions.
24. On June 5, 2018, a prehearing conference was held at which parties announced an
agreement in principle with regard to all remaining issues in the matter with the exception
of the DOE Pantex billing dispute issues. The ALJs admitted additional evidence for this
docket. The parties requested that issues relating to the DOE's Pantex billing dispute be
severed from this case.
25. On June 7, 2018, the ALJs issued Order No. 12, memorializing prehearing conference,
admitting evidence, severing certain DOE issues and establishing a new docket, and
setting deadline to file settlement materials or a status report. Docket No. 48440, Dispute
Between the US Department of Energy and Southwestern Public Service Company
Concerning the Pantex Facility and Pantex Wind Farms (Severed From Docket 47527)
was established for the severed DOE issues.
26. On June 29, 2018, SPS filed the agreement, which resolved all remaining issues in this
proceeding. All but two parties joined the agreement. GSEC did not sign, but does not
oppose the agreement. Mr. Nathan Porterfield's position on the agreement is unknown.
27. On July _, 2018 SPS and Staff presented testimony in support of the agreement.
PUC Docket No. 47527 Proposed Order
SOAH Docket No 473-17-5771 Attachment C to the Unopposed Stipulation
- 5-
36
470
28. On July , 2018, SPS filed an unopposed motion to admit evidence to support the
agreement and to remand the case to the Commission.
29. On July , 2018, the ALJs issued SOAR Order No. 13 admitting evidence to support
the agreement, remanding the case to the Commission, and dismissing the SOAH docket.
Description of the Agreement
30. The Signatories submitted the agreement to the Commission as representing a just and
reasonable disposition of the issues related to this docket consistent with the public
interest. The agreement is a black box settlement for all revenue requirements issues
concerning Texas retail rates except for specifications detailed in the agreement
concerning: Depreciation Expense; Financial Items; the TCJA; Capital Additions; the
Pension and Other Post -Employment Benefit (OPEB) Expense Tracker; and Margins on
Off -System Energy Sales.
Revenue Requirement, Base Rates and the TCRF
31. There is a change of zero dollars in SPS's net revenues by maintaining the base rates set
in Docket No. 455249 and the TCRF approved in Docket No. 46877.10
32. SPS is allowed to recoup the TCRF rider revenue it would have billed (revenue to be
recouped) had it not ceased billing the TCRF rider for usage during the period January
23, 2018 through June 10, 2018 (recoupment period). SPS will determine the revenue to
be recouped by rebilling customer usage for the recoupment period. By November 30,
2018, SPS will file an application requesting approval of the specific TCRF recoupment
rider charges.
33. In calculating the revenue to be recouped, SPS will include the revenue that would have
been billed to all service schedules subject to the TCRF established in Docket No. 46877,
but the TCRF recoupment rider will be designed so that certain service schedules
(exempt service schedules) will be charged zero dollars under the TCRF recoupment
rider and the revenue that would have been recouped from the exempt service schedules
9 Application of Southwestern Public Service Company for Authority 10 Change Rate, Docket No. 45524,
Order (Jan. 26, 2017).
1 D Application of Southwestern Public Service Company for Approval of Transmission Cost Recovery
Factor, Docket No. 46877, Order (Jun. 29, 2017).
PUC Docket No. 47527 Proposed Order
SOAH Docket No. 473-17-5771 Attacltntent C to the Unopposed Stipulation
- 6-
37
471
will instead be collected from the other service schedules that are subject to the TCRF
established in Docket No. 46877 (paying service schedules). The paying service
schedules will be responsible for the revenue that otherwise would be recouped from the
exempt service schedules on an equal percentage base rate (including TCRF) basis using
Updated Test Year billing determinants. The exempt service schedules are: Secondary
General Service; Primary General Service; Large School; and Small Municipal and
School Service.
Depreciation Expense
34. There will be no change in SPS's existing Commission -approved depreciation rates,
except in relation to the Tolk Generating Station Units 1 and 2.
35. The depreciation rates for Tolk Generation Station Units 1 and 2 attached to the
agreement are effective as of January 23, 2018.
36. SPS agreed to update its Tolk Station economic life analysis and include it in SPS's next
Texas retail base rate case application.
Financial Items
37. For Allowance for Funds Used During Construction purposes only, SPS will use a 9.5%
Return on Equity in conjunction with using its actual capital structure per the instructions
in the Uniform System of Accounts.
Tax Cuts and Jobs Act
38. SPS's Application as modified by the agreement and this Order incorporates the full
effects of the TCJA. The relate -back date in this rate case is January 23, 2018, which is
two days before the Commission issued its order in Project No. 47945, Proceeding to
Investigate and Address the Effects of the Tax Cuts and Jobs Act of 2017 on the Rates of
Texas Investor -Owned Utility Companies.
a. With regard to the reduction in the corporate federal income tax rate from 35% to
21% and the corresponding change to SPS's income tax expense:
i. The evidence presented in SPS's rebuttal cost of service and Staff's cost of
service in its direct case calculated SPS's federal income tax expense
using the 21% tax rate. SPS's and Staff's testimony in support of the
agreement further provides evidence of the incorporation of the 21%
PUC Docket No. 47527 Proposed Order
SOAH Docket No. 473-17-5771 Attachment C to the Unopposed Stipulation
7-
38
472
reduction in the corporate federal income tax rate and the corresponding
change to SPS's income tax expense.
ii. The disposition of the regulatory liability the Commission directed SPS to
establish in Project No. 47945 regarding the reduction in the corporate tax
rate is resolved through the base rates established in this case pursuant to
the settlement. SPS has no refund or bill credit obligation regarding that
regulatory liability.
b. With regard to the excess Accumulated Deferred Federal Income Taxes (ADFIT)
and Net Operating Loss (NOL) -related balances resulting from the TCJA:
The evidence presented in SPS's rebuttal cost of service and Staff's cost of
service in its direct case reflected amortizations of excess ADFIT balances
for protected and unprotected plant items, excess ADFIT balances for non -
plant items, and excess NOL -related balances resulting from the TCJA as
restated for the June 30, 2017 Updated Test Year. This is further
supported by SPS's testimony in support of stipulation.
ii. SPS acknowledges that it is obligated to continue to unwind its excess
ADFIT and NOL -related balances resulting from the change in tax rates
under the TCJA, and that continued unwinding will be reflected in the
calculation of SPS's cost of service in future base rate cases along with the
calculation of all other components of the cost of service.
iii. For the Updated Test Year ending June 30, 2017, the disposition of the
regulatory liability the Commission directed SPS to establish in Project
No. 47945 regarding the excess ADFIT and NOL -related balances is
resolved through the rates established under this Order and SPS's
obligation to continue unwinding those balances in future rate cases.
iv. In future rate cases, SPS will continue to unwind the excess ADFIT
balances associated with protected plant items based on the Average Rate
Assumption Method (ARAM), which is the amortization period SPS used
to calculate the unwinding of this category of excess ADFIT in its rebuttal
PUC Docket No. 47527 Proposed Order
SOAR Docket No. 473-17-5771 Attachment C to the Unopposed Stipulation
- 8-
39
473
cost of service, and which Staff also used in its cost of service.
v. In its rebuttal cost of service, SPS unwound the excess ADFIT balances
associated with unprotected plant items based on the ARAM. The parties
retain the right to address the appropriate amortization of the remaining
balances of ADFIT for unprotected plant items in SPS's next rate case.
vi. In future rate cases, SPS will continue to unwind the excess ADFIT
balances associated with non -plant items using a five-year amortization
period, which is the amortization period SPS used to calculate the
unwinding of this category of excess ADFIT in its rebuttal cost of service.
vii. In future rate cases, SPS will continue to unwind the excess NOL -related
balances over a 44 -year period, the average ARAM period, which is the
amortization period SPS used to calculate the unwinding of the excess
NOL -related balances in its rebuttal cost of service, and which Staff also
used in its cost of service.
viii. In future rate cases, SPS will address its excess ADFIT balances, and the
unwinding of those balances, associated with protected and unprotected
plant items, non -plant items, and NOL -related balances that may have
accrued from the end of the Updated Test Year in this case (June 30,
2017) through December 31, 2017.
Capital Additions
39. The capital additions that SPS closed to plant in service during the period of January 1,
2016 through June 30, 2017 that are included in SPS's Updated Test Year rate base are
reasonable and necessary.
Pension and OPEB Expense Tracker
40. The pension and OPEB expense tracker balance as of June 30, 2017, set forth in
Attachment B to the agreement, will be amortized over a 24 -month period starting
February I, 2018. Any remaining unamortized amounts can be included in a subsequent
base rate case filing and are deemed reasonable and necessary.
PUC Docket No. 47527 Proposed Order
SOAHDocket No. 473-17-5771 Attachment Cto the Unopposed Stipulation
- 9-
40
474
41. The baseline for the pension and OPEB expense tracker as of July 1, 2017 is set forth in
Attachment B to the agreement.
Margins on Off -System Energy Sales
42. SPS has agreed that for calculating eligible fuel expense from the date of the Order in this
case going forward until the earlier of the date of the final order in SPS's next fuel
reconciliation date or the relate -back date in SPS's next base rate case, SPS will credit
Texas retail customers with 100% of the Texas retail margins on generation book off -
system energy sales.
Demand and Enemy Loss Factors
43. SPS's line loss study presented in this case is approved and the resulting demand and
energy Toss factors are approved. The effective date of the new demand and energy loss
factors is February 1, 2018.
Rate Case Expenses
44. The base rates approved in this Order do not include rate case expenses, which will be
addressed in Commission Docket No. 47588. SPS has agreed to cap its request for rate
case expenses associated with Docket No. 47527 to $1.45 million related to SPS's rate
case expenses and AXM's rate case expenses and will nonetheless reimburse AXM's rate
case expenses. The cap in Docket No. 47588 applies only to rate case expenses
associated with Docket No. 47527 and does not apply to SPS's request for the rate case
expenses, including AXM's, for Docket Nos. 46025 (fuel reconciliation) and 46877
(TCRF).
Timing ofNext Rate Case
45. SPS has confirmed it will file its next base rate case no later than December 31, 2019.
TCRF, Distribution Cost Recovery Factor (DCRF), and Purchased Power Cost Recovery
Factor (PCRF) Filings
46. SPS has agreed to not file for a TCRF, DCRF, or PCRF until after the Commission issues
its final order in the next SPS rate case.
Renewable Enemy Credits (RECs)
47. Bundled Texas -generated RECs will be priced at $0.27 starting on June 1, 2018.
PUC Docket No. 47527 Proposed Order
SOAH Docket No. 473-17-5771 Attachment C to the Unopposed Stipulation
- 10-
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475
48. The Texas Commission will establish the value for Texas -generated bundled RECs and
the New Mexico Public Regulation Commission will establish the value for New
Mexico -generated bundled RECs.
Transition Plan to Eliminate the Residential Space Heatinz (RSH) Rate
49. Under the agreement SPS has agreed to propose a Residential Service (RS) rate design in
its next base rate case that eliminates the RSH Rider consistent with the RS rate design
proposed in this rate case. The new rate design for the Residential class will be designed
to moderate the effect on RSH customers of eliminating the RSH option. The new rate
design is intended to be revised or eliminated in future rate proceedings as the need to
moderate the effect of the elimination of the RSH Rider on RSH customers diminishes.
SPS agreed to make available upon request cost and billing determinant information
necessary to calculate RS rates based on initial consumption band alternatives of 400
kilowatt-hours (kWh), 500 kWh, 600 kWh, 700 kWh, 800 kWh, 900 kWh, 1,000 kWh,
1,100 kWh, and 1,200 kWh.
50. If, as in Docket No. 45524, further mitigation of rate impacts for RSH customers is
deemed necessary, SPS may propose a temporary rider designed to provide a credit per
kWh to all Residential customers for above-average residential consumption during the
winter months as defined in the current RS rate tariff (billing months of October through
May), to be phased out over a period of time. The cost of the credit will be recovered
through an increase to the RS energy charge throughout the year, with the increase to be
phased out concurrent with the phase-out of the credit and the phase-out of the RSH rider,
in a manner designed to be revenue -neutral for SPS. The temporary rider will end at the
conclusion of the summer months as defined in the current RS rate tariff (billing months
of June through September) in the year after the effective date of the new rates set in
SPS's next base rate case, unless SPS, Staff, and OPUC jointly recommend a different
ending date and the Commission approves that date. Rate changes under the temporary
rider and the elimination of the rider shall not occur during the winter months (as defined
in the current RS rate tariff). The target end date for the temporary rider is the end of the
summer period concluding September 30, 2020.
PUC Docket No. 47527 Proposed Order
SOAH Docket No, 473-!7-5771 Attachment C to the Unopposed Stipulation
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476
51. SPS agrees to continue to implement the plan to eliminate the RSH Rider developed in
cooperation with Staff and OPUC. SPS agrees to implement the plans prior to the
conclusion of its next base rate case.
52. Beginning with SPS's next base rate case, any cap on the number of customers joining
the residential time -of -use (TOU) rate plans will not include a limit on RSH customers
seeking to participate in the TOU rate plans.
Abandonment of Appeal of Docket No. 43695
53. SPS has abandoned its appeal from Docket No. 43695.
Cash Working Capital for Earnings Monitoring Reports
54. For preparation of SPS's Earnings Monitoring Reports for reporting years 2018 and
2019, SPS's total company Cash Working Capital is $-16,753,708 and SPS's Texas retail
amount is $-9,134,277.
Classes for SPS Energy Efficiency Cost Recovery Factor (EECRF) Filings
55. For all SPS EECRF cases filed before the final order in SPS's next base rate case
becomes final, as defined under Tex. Govt. Code § 2001.144, the classes approved in
Docket No. 4591611 will: (a) continue to be the classes for purposes of SPS's EECRF
cases; and (b) be considered the rate classes in SPS's "most recent base -rate proceeding"
under 16 TAC § 25.181(c)(49). Those classes are:
Residential Service;
Small General Service;
Secondary General Service;
Primary General Service;
Small Municipal and School Service;
Large Municipal Service; and
Large School Service.
11 Application of Southwestern Public Service Company to Adjust Its Energy Efficiency Cost Recovery
Factor, Docket No. 45916, Order at Finding of Fact No. 23 (Sept. 23, 2016).
PUC Docket No. 47527 Proposed Order
SOAR Docket No. 473-17-5771 Attachment Cto the Unopposed Stipulation
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477
Solar PPAs
54. SPS's request that the Commission find that SPS was prudent to enter into the purchased
power agreements with NextEra Energy Resources Acquisition, LLC for the Roswell
Solar and Chaves County Solar facilities (collectively, Solar PPAs) should be deferred to
SPS's next fuel reconciliation.
III. Conclusions of Law
1. SPS is a public utility as that term is defined in PURA § 11.004(1) and an electric utility
as that term is defined in PURA § 31.002(6).
2. The Commission exercises regulatory authority over SPS and over the subject matter of
this application under PURA §§ 14.001, 32.001, 36.001-36.112, and 36.211, and under
16 Tex. Admin. Code (TAC) § 25.231.
3. The Commission has jurisdiction over an appeal from municipalities' rate proceedings
under PURA § 33.051.
4. SOAH exercised jurisdiction over this proceeding under PURA § 14.053 and Tex. Gov't
Ann. § 2003.049.12
5. This docket was processed in accordance with the requirements of PURA, the Texas
Administrative Procedure Act, and Commission rules.13
6. SPS provided adequate notice of its application in compliance with PURA § 36.103 and
16 TAC § 22.51.
7. This docket contains no remaining contested issues of fact or law.
8. The agreement, taken as a whole, is a just and reasonable resolution of all the issues it
addresses, results in just and reasonable rates, terms, and conditions, is supported by a
preponderance of the credible evidence in the record, is consistent with the relevant
provisions of PURA, and is consistent with the public interest.
9. SPS's rates resulting from the agreement are just and reasonable and meet the
requirements of PURA § 36.003.
10. This application may be approved without a hearing under the Administrative Procedure
Act and Commission rules.
12 Tex, Gov't Code Ann. § 2003.049 (West 2016).
13 Tex. Gov't Code Ann. § 2001.001-.902 (West 2016 & Supp. 2017) (APA).
PUC Docket No. 47527 Proposed Order
SOAH Docket 14o. 473-17-5771 Attachment Cto the Unopposed Stipulation
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478
11. The requirements for informal disposition under 16 TAC § 22.35 have been met in this
proceeding.
IV. Ordering Paragraphs
In accordance with these findings of fact and conclusions of law, the Commission issues
the following orders:
1. The Commission approves SPS's application, as modified by the agreement and this
Order.
2. Consistent with the agreement and this Order, the rates, terms and conditions described in
this Order are approved.
3. SPS is authorized to file an application to implement the TCRF recoupment rider to
recoup the revenue it would have billed for usage during the period January 23, 2018
through June 10, 2018.
4. The depreciation rates for the Tolk Generating Units 1 and 2 that are attached to the
agreement are approved and are effective as of January 23, 2018.
5. SPS has no refund or bill credit obligation for the regulatory liability the Commission
directed SPS to establish in Project No. 47945 regarding the reduction in the corporate
tax rate.
6. SPS shall continue to unwind its excess ADFIT and NOL -related balances resulting from
the change in tax rates under the TCJA as set out in finding of fact 38b. Parties retain the
right to address the appropriate amortization period of the remaining ADFIT balances for
unprotected plant items in SPS's next rate case.
7. SPS's line loss study presented in this case is approved and the resulting demand and
energy loss factors are approved. The effective date of the new demand and energy Loss
factors is February 1, 2018.
8. SPS shall comply with each provision of the agreement.
9. Entry of this Order does not indicate the Commission's endorsement or approval of any
principle or methodology that may underlie the agreement. Entry of this Order consistent
with the agreement shall not be regarded as binding holding or precedent as to the
appropriateness of any principle or methodology underlying the agreement.
PUC Docket No. 47527 Proposed Order
SOAH Docket No. 473-17-5771 Attachment C to the Unopposed Stipulation
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479
10. All other motions, and any other requests for general or specific relief, if not expressly
granted, are denied.
Signed at Austin, Texas the
day of 2018.
PUBLIC UTILITY COMMISSION OF TEXAS
DEANN T. WALKER, CHAIRMAN
ARTHUR C. D'ANDREA, COMMISSIONER
SHELLY BOTKIN, COMMISSIONER
PUC Docket No. 47527 Proposed Order
SOAH Docket No. 473-17-5771 Attachment C to the Unopposed Stipulation
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