Xcel application to PUC re: SolarRewards in Boulder

8/13/2019 Xcel application to PUC re: SolarRewards in Boulder

1/20

BEFORE THE PUBLIC UTILITIES COMMISSIONO THE STATE OF COLORADO

IN THE MATTER OF THE APPLICATION OFPUBLIC SERVICE COMPANY OFCOLORADO TO ADDRESS VOLUNTARYSERVICE OFFERINGS IN TH E CITY OFBOULDER

))) DOCKET NO. _))

VERIFIED APPLICATION OF PUBLIC SERVICE COMPANY OF COLORADOTO ADDRESS DEMAND SIDE MANAGEMENT PROGRAMS, SOLAR REWARDSPROGRAMS, AND SOLAR REWARDS COMMUNITY PROGRAMIN T HE C IT Y OF BOULDER, COLORADO AS A RESULT OF

BOULDER S NOTICE OF INTENT TO ACQUIREINTRODUCTION

Public Service Company of Colorado ( Public Service or Company ) herebyapplies to the Commission to address ho w the Company should continue to offerelectric demand side management ( DSM ) programs, Solar*Rewards programs, andthe Solar*Rewards Community (community solar gardens) program to customers withinthe City of Boulder, Colorado, given the City s recent action of serving the Companywith Boulder s Notice of Intent to Acquire Public Service s electric business in Boulder.These voluntary programs provide long term benefi ts to the utility system. If continuedin their current form, and if the City completes its condemnation actions, then theseprograms would benefit a ne w Boulder municipal utility and not the Public Servicesystem. Public Service does not believe it is appropriate for our non-Boulder customersto subsidize a newly formed Boulder municipal utility. It is important to address nowho w to avoid any subsidization of Boulder from these voluntary Public Service customerprograms.


2/20

PROPOSED CH NGES TO VOLUNT RY PROGR MS OFFERED IN OULDERIn our Application, we are requesting the Commission s permission to make the

following program modifications for our Boulder customers and we are requestingwaivers of Commission rules and modifications of past Commission orders as may benecessary for us to implement these changes:

We request that we be authorized to include a termination provision in all of ournew Boulder Solar*Rewards contracts that would allow the Company toterminate our obligations to purchase energy and renewable energy credits( RECs ) from our customers when and if a cut-over date occurs. This wouldbe the date the City of Boulder may assume load serving responsibility to ourcustomers.

We request that we be permitted to modify our Customer-Owned SmallSolar*Rewards offering for Boulder customers by making participants contractspay for performance, similar to our other Solar*Rewards offerings.

We request that we be allowed to limit new participation of Boulder customers inour DSM programs so that the level of costs that we incur to fund new BoulderDSM participation in each year does not exceed the DSM electric revenuereceived from all of our Boulder customers in that year. Excluded from thislimitation would be our market transformation programs because of the difficultyin tracking the geographic locations benefitted from these programs.

Public Service requests Commission approval to defer offering ourSolar*Rewards Community (community solar gardens) program to Boulder

2


3/20

customers unless and until such time as Boulder determines not to proceed withthe formation of a municipal electric utility.

RECENT CTIONS T KEN Y OULDER TO FORM MUNICIP L UTILITY

On August 20, 2013, the Boulder City Council passed Ordinance No. 7918, anOrdinance Authorizing the Acquisition of Property Interests Owned by Public ServiceCompany of Colorado, D/B/A Xcel Energy, By Negotiation and Purchase or Through thePower of Eminent Domain, and Setting Forth Related Details. This ordinance authorizesthe Boulder City Manager to acquire the Property Interests and Assets of Public Servicein the Acquisition Area set forth in Ordinance No. 7918 by negotiation or by the exerciseof eminent domain and authorizes the city attorney to initiate condemnationproceedings. The Authorization Area set forth in Ordinance No. 7918 includes areasboth within and beyond the City of Boulder and includes Public Service s transmissionfacilities located mostly outside the City of Boulder that are used to serve customersboth within and beyond the City of Boulder.

1 As Public Service demonstrated to the Commission in Docket No. 13D-0498E, the City hasannounced its intention to serve Public Service customers outside City limits and to acquiremultiple facilities that Public Service relies upon to serve our customers both within and withoutthe City of Boulder. By Decisions No. C13-1350 October 29, 2013) and C13-1550 December18, 2013), the Commission made it clear that customers outside Boulder city limits and allfacilities used in whole or in part to serve customers outside Boulder city limits are subject tothis Commission s jurisdiction. The Commission also ruled that Boulder must obtainCommission approval for the transfer to Boulder of customers and facilities prior to commencinga condemnation action. To our knowledge Boulder has not yet sought Commission approval ofany facility or customer transfer. Boulder has appealed these Commission decisions to theBoulder District Court; the pending appeal is Case No. 2014-CV-030047.Unless and until there is a ruling by the Commission that Public Service s service territorycertificate to serve Boulder County customers outside the city limits of Boulder is no longervalid, Public Service has the exclusive right and obligation to serve these Boulder Countycustomers. As such, the Company is t asking to modify in any way the terms and conditionsof our voluntary programs to our Boulder County customers outside the city limits of Boulder.While it is not clear from the City s Notice of Intent to. Acquire whether the City still intends to


4/20

On January 6, 2014, the City served Public Service with a statutory Notice ofIntent to Acquire, pursuant to C.R.S. 38-1-121. A copy of that Notice, which includes acopy of Ordinance No. 7918, is attached as Exhibit A. A Notice of Intent to Acquire isthe first legal step required under Title 38 of the Colorado Revised Statutes that must beundertaken by the City in order to exercise its power of eminent domain. The Notice ofIntent to Acquire does not mention DSM investments, Solar*Rewards contracts orSolar*Rewards Community Contracts.

CKGROUND ON COMMISSION RULINGSWITH RESPECT TO PU LIC SERVICE VOLUNT RY PROGR MS

On February 17, 2012, Public Service applied to the Commission forauthorization to change the terms of the renewable energy, energy efficiency, andvoluntary green energy programs offered to customers in Boulder. We argued at thattime that the preliminary actions taken by the City of Boulder by February 2012 to forma municipal utility provided a reasonable basis to consider our Boulder customers as nolonger similarly situated to customers elsewhere on our electric system; we argued,therefore, that it would be appropriate to modify our voluntary program offerings toreflect the possibility that Boulder would proceed with acquiring the Public Serviceelectric business in Boulder and forming a municipal utility.serve these Boulder County customers, the Company does not agree with Boulder s assertionsthat it can just take them through the exercise of eminent domain. It is unclear whether Boulder will attempt to acquire our existing contracts under theseprograms through the exercise of eminent domain. What is clear is that they will be damagedby Boulder s exercise of eminent domain and Public Service will seek compensation for eitherthe taking or damage of them in any eminent domain proceeding. Public Service also reservesall rights to challenge Boulder s ability to condemn all or some parts of our electric business andto seek just compensation for all aspects of our facilities, property or business that may be takenor damaged by Boulder s threatened condemnation. However, addressing the voluntaryprograms discussed in this Application on an ongoing basis will limit the issues that need to belitigated in a condemnation case and best protect the Company s non-Boulder customers fromthe possible risk of subsidizing a new Boulder utility. .

4


5/20

By Decision No. C12-0798 (July 13, 2012) in Docket No. 12A-155E, theCommission dismissed Public Service s application, without prejudice, on the groundsthat the relief Public Service sought was premature at that time. The Commission reliedupon the argument raised by several parties that the Boulder City Council had not yetmade any definitive decision regarding the acquisition of Public Service s electricdistribution system. The Commission also relied upon statements by the City of Boulderthat under the Boulder City Charter it still had to demonstrate to a third partyindependent expert that municipalization would be feasible as a condition precedent tomoving forward with municipalization.

As demonstrated by Exhibit A, there is now no question that this issue is ripe forconsideration by this Commission. The Boulder City Council has not only made findingsthat it believes it has complied with all conditions precedent to the acquisition of thedistribution and transmission systems described herein and authorized the exercise ofthe power of eminent domain to acquire Public Service s electric business, the City hasnow taken the first legal step under state law to exercise its eminent domain powers.Now is clearly the time for the Commission to address how our non-Boulder customerscan be protected from further subsidizing a new Boulder municipal utility.

The Notice of Intent to Acquire (Exhibit A) does not list DSM investments orSolar*Rewards contracts as property that the City intends to acquire. Cityrepresentatives have stated that they do not intend to take these contracts through theexercise of eminent domain. The problem is that a City utility will receive the benefits ofthese investments merely by becoming the utility serving the City - these investmentspay for road reductions, renewable energy supply, and emission reductions that will


6/20

benefit the City, not Public Service, upon any transfer of the service territory. PublicService will seek compensation for these damages to our prior investments in thecondemnation proceedinq. The issue that we bring to the Commission s attention nowis how to avoid creating further damages or loss of benefits by continuing theseprograms in Boulder under their current terms. Without some certainty that Boulder iswilling to compensate Public Service for the benefits the City will derive from theseadditional investments, continuation of these programs without change in Boulder nowcould result in significant subsidies flowing from our non-Boulder customers to aBoulder municipal utility. Such subsidies would definitely not be in the public interest.

Public Service has once again made an offer to the Boulder City Attorney tocontinue all voluntary programs in Boulder without change if the City would commit tocompensate Public Service for the benefits that a City utility will receive from theseprograms. See Exhibit B. To date Boulder has not agreed to reimburse Public Servicefor any of these program expenditures.

In Decision No. C12-0798 in Docket No. 12A-155E, the Commission made itclear that the Commission had concerns about our non-Boulder customers subsidizinga Boulder municipal utility, but the Commission did not want to act prematurely. Actionby the Commission is no longer premature. The time to protect Public Service s non-Boulder customers from paying for programs that benefit a Boulder municipal utility isnow.

3 As with any matter that is litigated, there is always uncertainty as to whether a party s positionwill be fully accepted by the court. Therefore, Public Service believes it is imperative to limit theCompany s exposure to additional damages related to these voluntary programs. To be clear, existing agreements would not be impacted by the clarifications that PublicService is seeking in this Application.


7/20

LEG L UTHORITY FOR TRE TING BOULDER CUSTOMERSDIFFERENTLY FROM NON BOULDER CUSTOMERS

Public Service believes that the Commission has ample authority to authorizedifferent terms and conditions for Public Service s voluntary programs offered in Boulderfrom the terms and conditions of these programs offered elsewhere in our serviceterritory. Under C.R.S. 40-3-106(1)(a), Public Service can have no unreasonabledifferences in our service offerings to similarly situated customers. In light of thepassage of Ordinance No. 7918 by the Boulder City Council and the issuance of theNotice of Intent to Acquire, we believe that for purposes of these voluntary programofferinqs our Boulder customers are no longer similarly situated to those elsewhere onour system, and that it would be reasonable to continue these programs in Boulderunder different terms and conditions, recognizing the loss of benefits to our electricsystem if and when the City assumes electric utility responsibility for Boulder.

Public Service recognizes that we continue to have the legal obligation to serveBoulder s electric load unless and until the City is able to form a municipal utility andcompletes all necessary steps to do so. As a result, Public Service continues to plan toserve Boulder s load reliably. However, this Application concerns voluntary programsthat provide benefits to our electric system as a whole, but also provide significantadditional benefits to the participants in the programs and the future utility serving thoseparticipants. We are concerned that the costs that we incur for new contracts withBoulder customers in these programs, costs which are only justified if the participantremains a Public Service customer for the life of the applicable program, will effectiveiybe shifted to other customers if Boulder customers depart our system due to a Boulder

7


8/20

municipalization. Further, while picking up the full costs, our customers would notreceive the full benefits - the benefits would be delivered to the new Boulder utility.

LONG TERM BENEFITS PROVIDED BY THESE VOLUNTARY PROGRAMSPublic Service currently offers our retail customers payments to acquire

resources, in the form of rebates or incentives, to install on the Public Service systemretail distributed generation ( Retail DG ) and various forms of demand sidemanagement. These customer payments are offered either under long-term contracts(for Solar*Rewards and Solar*Rewards Community) or contracts or rebates for DSMprogram applications. We provide these payments to promote energy efficiencymeasures and to promote the development of Retail DG resources. These investmentshelp Public Service to avoid alternative forms of generation that would otherwise berequired to serve our customer load. The costs of these payments are funded by allretail customers, whether or not they participate in the programs or are recipients of thepayments because the retail customers are served by the utility system that receivesthe long-term benefits of these programs.

If the City of Boulder acquires Public Service s electric business in Boulder, theCity, not Public Service and our non-Boulder customers, will be the long-termbeneficiary of the load reduction benefits and solar generation acquired by the paymentof solar incentives and DSM rebates. Our concerns regarding our Boulder customersparticipation in these programs are exacerbated by the fact that our Boulder customershave already participated in these programs at a higher rate than customers elsewhereon our retail system. For example, the City of Boulder constitutes approximately 4 4 ofour total retail revenue, but approximately 1 of our Solar*Rewards dollars and


9/20

approximately 5.2 of our DSM dollars were spent in 2011 to provide programs andincentives to Boulder customers, including to the City Boulder itself. In 2012 thecorresponding percentages were A of our Solar*Rewards dollars and 5.4 of ourDSM dollars were spent in Boulder. In the past this level of participation was not ofconcern - indeed, it was welcome. But now it is not appropriate to continue to providethese subsidies to Boulder, particularly if Boulder follows through with its plan, PublicService s customers will no longer receive the solar energy or receive the energyefficiency and demand reduction benefits for which they would be paying.

Moreover, given the limited funds available for these programs, these fundsshould be directed to customers who will stay on and benefit from the Public Servicesystem, not to customers who are planning to leave. That being said, our preferredapproach remains to find a way to continue these programs in Boulder underreasonable terms and conditions, recognizing the uncertainty created by the City sactions.

DETAILS OF VOLUNTARY PROGRAMS ANDCHANGES REQUESTED FOR BOULDER CUSTOMERSWe address next the voluntary programs that Public Service currently offers in

Boulder that would be affected by any new Boulder municipal electric utility and we setforth the changes to these programs that we request the Commission to authorize.

A. Solar*RewardsPublic Service offers the Solar*Rewards program to encourage our customers to

install retail distributed generation upon which Public Service relies as a generationresource to serve our system load and upon which Public Service relies to meet our


10/20

obligations under the state Renewable Energy Standard. Retail distributed generationis defined under C.R.S. 40-2-124 (1)(a)(VIII), in pertinent part, as follows:

Retail distributed generation means a renewable energy resource that islocated on the site of a customer s facilities and is interconnected on thecustomer s side of the utility meter. In addition, retail distributed generation shallprovide electric energy primarily to serve the customer s load and shall be sizedto supply no more than one hundred twenty percent of the average annualconsumptions electricity by the customer at that site....Under our Solar*Rewards program, we pay incentives for the installation of

photovoltaic ( PV ) panels for long-term generation and delivery of solar energy into oursystem and we contract for the Renewable Energy Credits ( REC ) from this resource.Participating retail customers contract with Public Service under Commission approvedrequirements that customers leave the solar panels in place for twenty (20) years (1) toprovide the energy that Public Service would otherwise be required to serve, and (2) toproduce RECs for Public Service to use toward meeting compliance with theRenewable Energy Standard. These Commission approved requirements areestablished in periodic Renewable Energy Standard Compliance Plans approved by theCommission. Commission Rules 3656(f) and (g) and Rules 3658(f)(VII)(A) and (8)require minimum terms of twenty (20) years for these contracts. Thus, incentives forsolar panel installations are given to obtain long-term generation at a site in our serviceterritory and to obtain RECs.

In addition to the underlying assumptions for retail distributed generation ( RetailDG ) contracts, it is important to remember that Public Service s ability to acquireEligible Energy Resources (renewable resources) is capped, by statute, by the retailrate impact limit. C.R.S. 40-2-124(1)(g)(1)(A) provides that customer bills may beraised by a maximum of two percent to pay for the incremental cost of renewable

10


11/20

energy. In other words, there are limited funds available for acquiring Retail DG andwhile the Company is permitted to and has developed a negative RESA balance, theCompany s goal is to reduce that balance. While some of our Solar*Rewards programs,including those for customer-sited PV systems from third-party PV developers, arestructured as pay for performance programs, our Customer-Owned Small 1 kWSolar*Rewards program is still front-end loaded, paying REC incentives over ten (10)years for twenty (20) years of RECs. Given that all of our Solar*Rewards offerings arepredicated upon customers (or successors) remaining on our system for twenty (20)years, we are proposing the following changes to our Solar*Rewards program offeringsfor Boulder customers:

We request that we be authorized to include a termination provision in our newBoulder Solar*Rewards contracts that would allow us to terminate obligations(other than certain provisions that should survive a termination such as theobligation to make final payment) upon a cut-over date - that is, on such dateas the City of Boulder may assume load serving responsibility to our customersin Boulder. We believe that the termination right may already be implicit in ouraqreernents. However, we believe that an express termination provision willprovide clarity to both the Company and customers in the event the cut-overdate occurs. This approach allows for continued participation in our program by

Public Service will be able to use the RECs that we acquire from Boulder customers prior totermination for compliance with the Retail DG standard even after these contracts areterminated. Under Commission rules, the RECs have a shelf-life of the year in which they aregenerated plus five years.6 Our applicable contracts are predicated upon our customers continuing to be our retailcustomer s, a requirement that will be impossible for Boulder customers to meet in the event thatBoulder becomes their retail supplier.

11


12/20

our Boulder customers in the meantime, but assures that the Company sobligation is over in the event these customers leave our system.

All our Boulder Solar*Rewards programs, except our Customer-Owned Small1 kW Solar*Rewards program, utilize pay for performance contracts basedon a twenty (20) year schedule. We request that we be permitted to modify ourCustomer-Owned Small 1 kW Solar*Rewards offering in the City of Boulder tomake it also a pure pay for performance contract, with the contract terminatingat the cut-over date to a Boulder municipal electric utility. If our Boulder contractsare modified in this way, we can avoid the potential problem of being contractedto make payments for benefits that we will not receive.In order for the Commission to authorize these requested program modifications,

it will need to waive certain Renewable Energy Standard rules, Rules 3650 et seq. Weask for such waivers as may be required to allow our request to become effective. Inparticular, we ask for waiver of Rules 3656(f) and (g), and 3658(f) (VII)(A) and (B) to theextent that they would otherwise require twenty (20) year contracts without a terminationright, and Rules 3658(e) and (f) to the extent that they would preclude treating Bouldercustomers differently from other customers for purposes of the Solar*Rewardsprograms.

B. DSM ProgramsThe rationale for establishing demand side management rebates is that these

DSM investments are reducing resource costs that would otherwise be incurred byPublic Service to serve Public Service load, and, therefore, all customers benefit fromthe payment of these rebates, whether or not they directly participate in the programs.

12


13/20

The Colorado General Assembly has endorsed the goal of minimizing the net presentvalue of revenue requirements by the establishment of energy savings and peakreduction goals to implement cost-effective electricity DSM programs to reduce theneed for additional resources. See C.R.S. 40-3.2-104. This public policy is likely toproduce benefits over time, although where a utility is long on generation as PublicService presently is, the benefits may be delayed. These DSM rebate payments aremade to our customers to reduce or manage their electricity consumption, because overtime it would be more expensive to install and operate generation to serve that sameconsumption.

However, not every DSM measure qualifies for rebates under our programs.Qualifying DSM programs must be determined to be cost effective and in the publicinterest by meeting the modified Total Resource Cost test. Simply stated, this testcompares the costs of a measure aga.inst its projected benefits over the expected life ofthe measure. The lives of the DSM measures offered in our programs vary in lengthwith an average life of approximately twelve 12) years - well beyond the point whereBoulder hopes to begin to operate its own municipal utility. Because we typically payrebates for DSM measures soon after installation and because our payments areintended to achieve long-term benefits, we are not indifferent as to where we implementthese measures.

Consequently, Public Service has a concern about continuing open-ended DSMinvestments in Boulder, unless the City agrees to compensate Public Service for theload reduction benefits that will accrue to a Boulder utility. Because Boulder has notagreed to date to provide any compensation to Public Service with respect to these

13


14/20

programs Public Service requests that we be authorized to limit the total amount of ourongoing DSM investment in Boulder in each year to the total amount of DSM relatedrevenue that we receive from our Boulder customers in each year.

Given that we have limited resources to implement these programs it isappropriate for us to direct the available resources that we have to achieve the publicpolicy goals underlying these programs toward those of our customers who have notexpressed an interest in possibly departing our system. For this reason one couldrationally conclude that we should seek to terminate our DSM offerings to our Bouldercustomers in their entirety at this time. However it is still not yet a ert inty that Boulderwill in fact depart from our system. We would rather avoid the disruption in our programefforts in Boulder until that certainty is known so long as we can do so in a manner thatminimizes the risk of our non Boulder customers subsidizing a Boulder utility.

We have developed our proposal relating to our DSM program offerings tobalance these two competing factors. Under our proposal we would continue to allowBoulder customers to participate in our DSM programs but subject to limitation. In thismanner we avoid the disruption that might occur were we to terminate the programscompletely in Boulder but at the same time lessen the potential level of cost shift thatcould result from a business as usual approach were we not to modify our programs.

We are excluding from our proposal market transformation programs such ashome lighting and computer efficiency due to the nature of the retail deliverymechanism and upstream incentive payment. In short there is little we can do to avoidBoulder customers from participating in these programs without creating additionalburdens on our delivery vendors.


15/20

C. Solar*Rewards ommunitySolarGardensBy statute, the community solar garden must sell the output from the community

solar garden to the utility that has the service territory in which the garden is located.See C.R.S. 40-2-127 5 b I . The utility is required to pay for the energy output fromthe solar garden through bill credits. If Boulder forms a municipal electric utility, anycommunity solar garden located in Boulder would have to sell its output to the City andthe City would have to issue the bill credits. Because of the uncertainty of which utilityPublic Service or the City would ultimately serve in Boulder once any new communitysolar gardens were constructed in Boulder, Public Service should not reasonably enterinto any new contracts with community solar gardens in Boulder or with any communitysolar gardens that have subscribers who live within Boulder, because of our inability tocovenant that we will be able to meet any long term contractual obligations with thegardens and/or their subscribers.

We also note that there are always limited funds available for community solargardens. Public Service has proposed to acquire 6.5 MW of new solar gardens in our2014 Renewable Energy Standard Compliance Plan, pending in Commission DocketNo. 13A-0836E. Given our belief that interest by other communities will exceed thislevel, we believe that our focus should be on awarding slots in this program tocommunity solar gardens that are expected to remain in our service territory.

CONCLUSIONPublic Service would like to continue to offer our voluntary programs in Boulder

uninterrupted. In order to do so, we need the cooperation of the City of Boulder inreaching an agreement that the City will assume all remaining contractual obligations

15


16/20

and compensate Public Service for any benefits received under these programs.Given the City s repeated offers in Docket No. 13D-0498E of its willingness to

work with the Commission to effectuate a smooth transition of electric service in Boulderfrom Public Service to the City, Public Service is hopeful that we will not need to restrictour programs in Boulder. If Boulder were to agree to assume Public Service sobligations under these voluntary programs if and when electric service in Boulder isprovided by a Boulder municipal utility, Public Service would be willing to withdraw thisApplication.

However, until Boulder shows such willingness to assume the obligations to payfor the benefits that a Boulder utility would receive from these voluntary programs,Public Service respectfully requests that the Commission authorize the Company tomodify these program offerings in Boulder in the manner set forth in this Application.

INFORMATION REQUIRED BY RULE 3002 b) AND c)1. Name and ddress of pplicant The Applicant is Public Service Company

of Colorado. Public Service s principal office is located at 1800 LarimerStreet, Suite 1400, Denver, Colorado 80202.

2. Name Under Which pplicant will Provide Service in Colorado Alloperations conducted by the Company in Colorado shall be conducted underthe name of Public Service Company of Colorado d/b/a Xcel Energy.

3. Representatives to Whom Inquiries Concerning the pplication Shouldbe Made. Copies of all notices, other correspondence, and all inquiriesconcerning this Application should be sent to:


17/20

Robin KittelDirector, Regulatory AdministrationXcel Energy Services Inc.1800 Larimer Street, Suite 1400Denver, Colorado 80202-5533Telephone: (303) 294-2242Email: [email protected] M. Connelly, 14451Managing AttorneyWilliam M. Dudley, 26735Assistant General CounselXcel Energy Services Inc.1800 Larimer Street, Suite 1100Denver, Colorado 80202-5533Telephone: (303) 294-2222 (Connelly)(303) 294-2842 (Dudley)Email: [email protected]@xcelenergy.com

4. greement to omply with 4 CCR 723-3002(b)(IV)-(VI). Public Service has read,and agrees to abide by, the provisions of 4 CCR 723-3002(b)(IV)-(VI).

5. Description of Existing p ~ r t i o n s and General olorado Service Area.-Public Service provides electric and gas public utility service in numerous areasthroughout the State of Colorado. The Company also provides steam utility servicewithin the downtown area of Denver. A full listing of Public Service s existingoperations and service area is set forth in Public Service s tariffs on file with theCommission.

6. Location of Hearing. The Company seeks a ruling on this application withouthearing. However, if a hearing is held on this Application, Public Service prefersthat the hearing be held at the Commission s offices in Denver, Colorado.

17


18/20

7. cknowledgment Public Service has read and agrees to abide by the provisionsof 4 CCR 723-3002 b) XI) A)- C).

8. Statement Under Oath. The undersigned counsel for Public Service states underpenalty of perjury that the contents of the Application are true, accurate, andcorrect.

9. Information Required by Rule 3002 c). Public Service hereby incorporates byreference the following information, which is on file with the Commission in DocketNo. 06M-525EG:a. A copy of Public Service s Amended Articles of Incorporation, which was last

filed on October 3, 2006;b. The name, business address and title of each of Public Service s officers and

directors, which was last filed on September 23, 2011;c. The names and addresses of affiliated companies that conduct business with

Public Service, which was last filed on March 23, 2011;d. The name and address of Public Service s agent for service of process, which

was last filed on October 3, 2006.e. A copy of Public Service s most recent audited balance sheet, income statement,

statement of retained earnings and statement of cash flows was last filed on April11,2013.


19/20

Dated this 28th day of January, 2014.

Respectfully submitted, ~ /h, Paula M. Connelly, 14451Managing AttorneyWilliam M. Dudley, 26735Assistant General CounselXcel Energy Services Inc.1800 Larimer Street, Suite 1100Denver, Colorado 80202-5533Telephone: 303) 294-2222 Connelly)303) 294-2842 Dudley)

Fax: 303)294-2988Email: [email protected]@xcelenergy.comttorneys for Public Service ompanyof olorado

19


20/20

BEFORE THE PUBLIC UTILITIES COMMISSIONOF THE STATE OF COLORADOIN THE M TTER OF THE APPLICATION OFPUBLIC SERVICE COMP NY OFCOLOR DO TO ADDRESS VOLUNT RYSERVICE OFFERINGS IN THE CITY OFOULDER

DOCKET NO. _

VERIFICATIONSTATE OF COLORADOCITY AND COUNTY OF DENVER SS:

I, Paula M. Connelly, being duly sworn, do hereby depose and state that I am theattorney for Public Service Company of Colorado, Applicant in the foregoing Application.Under penalties of perjury, I declare that all statements made in the Application are true,accurate and correct. Subscribed and sworn to before me this 28th day of January, 2014.

.My Commission expires:YRENE ANUf=JezNOTARY PUBLIC

STATE OF COLORADONOTARY 9874 49 94 IMYCOMMISSION EXPIRES SEPTEMBER 28.2 6

Xcel application to PUC re: SolarRewards in Boulder

Documents

Transcript of Xcel application to PUC re: SolarRewards in Boulder