I am writing to complain of Xcel Energy Minnesota’s proposed three year 20% increase in residential rates; an increase of 35% since 2013 for basic service charges and energy&demand rates; • As proposed, the current $10.00 underground line rate goes up 22% in 2018, • As proposed, the summer/winter energy current rate of 9.395¢/8.040¢ goes up 18% in 2018. It would seem the proposed rates are driven by Xcel’s submitted 4.5%CAGR base capital plan. Xcel also notes an “upside” $1.6Bn capital potential over base case which seems driven in large part to renewables and “steel for fuel”. A stunning 20% proposed rate increase when coupled with an aspirational 2020E ROE (Xcel Energy Investor Meeting December 3, 2015), I am concerned how soon this “upside” to Xcel falls on the backsides of residential rate payers; new riders on top of 2017 or 2018 authorized rates? and an ongoing escalation of planned dividend payouts meaning more rate increases to pay for those?
I also write to comment on Xcel’s request for a multiyear plan of 5 years. I urge the commission at this time to turn down the request as premature. The current proposal is just the first 3 year multi year rate plan. Even at this stage, with a 3 year plan as compared to one year plans, it would seem logical the assurances of a 3 year approved rate plan would justify a reduced authorized ROE. Arguably, an authorized 5 year rate plan should have an even further reduced authorized ROE.
Considering this proposal is the first multi year rate plan, it would seem after a minimum of 3 cycles of 3 year multi year rate plans, in the 10th year (at the earliest), Xcel could, if they desire at that time, apply for a 5 year multiyear rate plan. At that time, the commission could “back test” as two 5 year multi year rate plans as basis to consider a new authorized 5 year plan. As I understand, across the industry, there are no proposed/approved/tested “performance standards”. From the Commission Action of Dec 22 regarding multi-year interim rate-increases “their legal, regulatory, and operational parameters are not yet widely understood”. I have seen mention of one potential penalty for gross failure against performance standards as denying the utility the rights to a monopoly. That seems hardly logical unless the commission had rights to transfer assets to a different (untested?) party or go through a 25 year buildout for a new monopoly? Given Xcel Energy Minnesota’s request for a multiyear rate plan, it would seem actions taken by the MPUC may set the benchmark for future (3 year or 5 year) multi year rate plan proposals. In this new era of multi year rate plans, dynamic industry change in access to and affordability of renewables, and Xcel’s “upside capital” steel for fuel initiative, I would urge the commission a.) to reduce residential rates from the 20% proposed increase, b.) tread judiciously and deliberately as a strategic model to vetting and authorizing multiyear rate plans, and c.) consider opening the door to other providers to supply cost effective renewables who are not saddled with potentially excess fossil fuel related assets. Is it time for the Commission to be “disruptive” not only in a move towards renewables, but also in who and how those renewables are created and delivered? I know the Commission is reviewing a multitude of rate plan requests. I would urge the Commission to direct significant resources to fully vet this 3 year proposal and at the expense of resources to one year proposals, if needed. As the first multi year rate plan, this deserves attention.

I'm not complaining that Xcel needs to raise their rates, but we do need to inform the public and at least make Xcel energy accountable, and get reliable measures on that accountability. As an Xcel customer I understand the need for raising the rates, but a 20 percent increase is absolutely unreasonable, and just plane robbery. If these rate increases are needed for using renewable sources, than ask the people that are demanding this to step up to the plate.

It is unreasonable to use my electric fees to pay for advertising and implementing a ( go green ) program that is based on fear and no factual evidence. Let alone charging us a 20 percent increase for this service.

If the best Xcel can do in service and quality is where were at, than we should look to another way of getting our energy delivered to our homes. Knowing this to be impossible at least make the renewables accountable for their costs and aspect Xcel to not only show these cost, but not to let them profit more from increasing cost to customers. We need to tie rate increases to cost reductions and increases in efficiencies, not increases in costs. This is the exact problem we have with government, we reward increases for added costs not for productivity increases. Please find a more economical and fair system of shoving another poor system down the throats of the general public.

comment...I have a simple response to the desire of Excel to charge more over a three year period. Why have they been promoting less use in both gas and electric. Getting the consumer to use better furnaces etc. And now they want to increase the rates. Something not right with that picture.

I don't understand why they can't get more efficient and have to continue to request double digit increases. I don't get that for my income. I lived in Florida for 7 months a year for the last 5 years. I get letters like this from Florida Power and Light, but they are talking about all the things they are doing to reduce rates and have done so as long as I have been here. Maybe Excel should contact the professionals at FPL and see if they can get some advice for reducing cost. Seems like they are not doing the best they could do.

Energy prices are crashing through the floor (Natural gas at $2.12 - down from over $5 two years ago; WTI Crude at $28.94 - down from over $100 two years ago; coal at $43.37 - down from over $60 two years ago) yet Excel Energy wants to increase rates? Something is not right with this picture. Could it be they see an opportunity to take advantage of their monopoly? Seems like a rate DECREASE would be more appropriate.

In a world where energy costs have dramatically decreased in the last year, will someone please explain to me how and why Xcel Energy should be allowed to increase the price ( to consumer ) of any type of fuel or energy ? It would only make sense to me that since our entire economy is pertty much based on the cost of fuel ( energy ) that every energy provider should be following suit and dramatically decreasing the cost ( to consumer ) of every type of fuel including but certainly not limited to the price the end user pays for electricity. It appears to me that ripping-off the consumer in this day and age has become so prevalent that it is just accepted as normal these days. You should be ashamed of yourselves Xcel Energy !

Given Xcel Energy's projected increase numbers for Residential - Overhead line service, starting with an average current monthly cost of $71.11, the 2016 interim increase of $4.20/mo, the 2017 increase of $7.92, and the 2018 increase of $9.24 yields a monthly cost of $92.47/mo. This is an increase of 30.04% over the 3 year period - not the stated 6.4%, 1.7%, and 1.7% total of 7.75%. Please take a careful look at the impact of their REAL increase when a retired customer like myself has received Social Security increases of 1.5%, 1.7%, and 0% over the past 3 years (2014, 2015, 2016). These (SSA) increases are based on projected cost of living formulas. It would seem Xcel Energy's projected cost of living increase is far greater than its customers. Maybe they need to be encouraged to manage their costs better so their customers can afford to heat (and cool) their homes.

Do not increase rates for each year beyond 2%, which is reasonable.

I agree with the other contributors here in that the proposed rate increase by Xcel is both outrageous and unwarranted. Fuel costs - which make up the bulk of energy production costs, have dropped more than 50% while increases in efficiencies have dramatically dropped demand for electricity... so why are they seeking the 20% increase? I respectfully request their request to be denied.

S&P Capital IQ's most recent Jan 23, 2016 Analyst's Risk Assessment on XEL includes "Our risk assessment reflects the steady cash flow that we expect from the regulated electric and gas utility operations, which have a relatively low-cost power supply, our view of a relatively healthy economy in most of the company's service territory and a generally supportive regulatory environment." Comment of a "generally supportive regulatory environment" is concerning during this time of another rate increase application and new initiative seeking multiyear rate plans.

I am retired and am opposed to a rate increase. I am on a fixed income and can ill afford a rate increase. Natural gas and oil prices are down and are not forecasted to rise significantly in the near future. Perhaps Xcel should look to reduce costs before asking for increase after increase. I would like to know how many aircraft Xcel either leases or owns and at what cost and I'd like some justification for this luxurious expense. I ask respectfully request that Xcel's request be denied.

Xcel Energy at it again! This is becoming a annual event! I have responded to these increases in the past as I believe that Excel Energy needs to take a long hard look at the business as there are ALWAYS ways to lower costs in order to keep from charging customers more. If you can't come up with any then you do not have the proper people in place! The organization needs to bring in individuals capable of finding and eliminating waste, instead of individuals that just want to raise rates. Stop using the environment card on consumers as a reason to raise the rates! What consumers are concerned about is the rates that they pay! What excel Energy needs to be concerned about is how to reduce emissions without raising rates every year! Again this should be accomplished by looking at the current business and eliminating inefficiencies or waste! I have said this before - Isn't it ironic that we are offered ideas on how to be more efficient with our energy in order to lower our cost, from the very business that supplies us our energy, only to have our rates increased. This is a lose/lose situation for the consumer. What we need is a win/win solution for both consumer and producer. This is not impossible, Excel needs to step up to the plate and stop taking the easy route!!

Profits for the 4th quarter and annual rise again at XCEL ENERGY were reported by the star tribune yesterday(page 2 business section). It never fails to amaze me how this "public" company keeps churning out dividends for their shareholders, and yet there they are every year with their hands out asking for ridiculous rate increases.Doesn't anyone see anything wrong with this picture? I especially like how they impose their hikes immediately, but when it comes time to refund users it takes them months to pay. I wish someone could explain to me why this company is allowed to operate in such a manner.

After getting my electric bill today and reading the insert with the bill, I want comment on their so called rate increase. Short answer: They don't need one. Since they have announced the interim rate increase, the electric has gone off twice. One time they were working on the lines behind my house without giving anyone any notice at all.

This current bill is higher than the previous bill. I am not running anything differently. By looking at my bill you would think I am running a window air conditioner. My gas bill is cheaper and that is my heating source. What the state needs to do is let another electric company come in and compete with Xcel for customers. Every year we go through this routine of Xcel wanting a rate increase. It might be warrented if they could keep the electric on all of the time. But they can't. They don't need another rate increase. It has been in the news this past year of people not making a liveable wage. If they want a rate increase, make sure people have a liveable wage. That isn't going to happen, so no rate increase. I read last month that Xcel wants to push these solar gardens and wind mills. We don't know where these solar gardens would be. How would we see any savings if we invested in these solar gardens? Is that why they want the rate increase? The commission needs to say no to a rate increase. Xcel still makes a profit. They want us to conserve energy but want to increase the rates. Make up your mind. You want us to conserve but you want us to pay more. Xcel pushes the flourescent lights. Guess what? Those don't work in every light fixture. How much of this rate increase is going to keeping Xcel's name on these sports buildings throughout the country? Once again the state needs to say no. I would love it if the state would also tell Xcel that they couldn't ask for a rate increase for five years. At least.

It seems like rate hikes are increasing far faster than cost of living, when all energy costs are decreasing. This doesn't make sense, even taking the cost of infrastructure into account.

I respectfully but strongly encourage the members of the MN PUC to deny Xcel Energy's request for a rate increase because such a request is not warranted by (1) the costs of fuel (which have declined to historic lows in many cases), (2) by the low levels of inflation, or (3) by otherwise serving the customer's good. So far as I can determine, this request is based on a desire to increase the company's dividends and financial reserves, and perhaps to invest in alternative fuels such as wind and solar, which have a much higher "sexy" rating than coal and natural gas. I do not deny Excel Energy the right or even perhaps the responsibility to engage in such practices under the right circumstances and for the right reasons, but these circumstances and reasons clearly do not exist in January 2016. While alternative fuels have become a legislative and political mandate, it is not right to levy the general public with drastic increases to pay for them, at least not at the present time, and likely not for the foreseeable future. Let those who wish to exercise their moral consciences and values in this way themselves contribute to the support of such green energy measures by paying an appropriately higher rate.

The only reason that I am aware of that might be a warrant for concern is the possible need to build new power plants in the future, given the ongoing commitment of federal executive and congressional leaders to increasing the population of the United States be means of immigration, both legal and illegal. (For more information, see the non-partisan organization NumbersUSA, which advocates sustainable immigration policies.) But given that Excel Energy is not speaking about increasing its power capacity to meet such demand, I can only conclude that this reason too is null and void.

I do not complain about the service offered by Excel, which seems to be in order in my neighborhood. Power outages are infrequent, and do not last long. Employees seem to be competent and polite. Let the commission note, however, that I do observe tree branches growing among residential power lines on a frequent basis. Yes, they got trimmed back after the last ice storm-induced power outage, but within 2 years, they were back again. This seems rather insufficient.

However, in conclusion and on a personal note, I have had professionals install recommended levels of insulation in my attic, as well as a high-efficiency wood fire place. I made these investments so I could enjoy life as I live within my means and control my energy usage. Yet, by raising the electricity rates so drastically, Excel Energy threatens my ability to live on a tight income and pay my own electric bill without having to resort to some kind of public assistance. That is not right, but that is why the PUC exists in the first place. Members of the MN PUC, evaluate legitimate business need and weigh it in light of the cost of fuels, low inflation, and the end users' needs. Please, do not grant this request.

"Monthly Social Security and Supplemental Security Income (SSI) benefits will not automatically increase in 2016 as there was no increase in the Consumer Price Index (CPI-W) from the third quarter of 2014 to the third quarter of 2015. " (Taken from www.ssa.gov concerning the 2016 Social Security Changes..., or, in this case no changes.) It is unrealistic to expect Social Security benefits to increase 20% in 2017. I wonder how many currently employed residential customers will realize a 20% increase in wages/earnings in 2017? Xcel Energy is asking for a 20% increase to residential rates in 2017. From where will this additional money come? I'd like to know, where are the cost saving measures from Exel Energy? Where are the efficiency gains from Exel Energy? And if this is merely a negotiating ploy (Ask for the sun and the stars; settle for the moon), shame on MPUC for permitting this issue to have gotten this far.

I respectfully but strongly encourage the members of the MN PUC to deny Xcel Energy's request for a rate increase because such a request is not warranted. This is yet another irrational attempt to push the financial burden of internal decisions onto consumers. It appears as though Xcel, among a multitude of other monopolizing companies, wastes no time pushing their abhorrent yearly rate increase requests, even though actual energy rates are rapidly declining everywhere you look. Don't be fooled people, this has little to do with alternative energies or new regulations. That's simply the facade that these companies use to push their rate increases. Remember, if we keep letting them get away with it, they'll keep doing it. I say again, please deny Xcel Energy's request.

Please deny Xcel Energy's requested rate increase. Plain and simple, if Xcel Energy wants a 20% rate increase than I and the rest of its customers deserve to know HOW my electricity is going to be worth 20% more. Will my lights burn brighter? Will my refrigerator cool faster? No, not really. All this will do is make my bill larger. It's all fun and games until you run out of other people's money.

Referring to Xcel's income statements posted here: http://amigobulls.com/stocks/XEL/income-statement/annual

I strongly encourage the MPUC to DENY Xcel Energy's requested rate increase. Cost of Good's sold decreased over 13% from 2014 to 2015. Gross Profit increased 7%, and the dividend per share increased 8%. Much of the expense increase is depreciation amortization. Xcel should not be looking for how they can increase consumer rates, but how they can lower them by becoming more efficient. They are profitable already without the need for a rate increase. Appears to me that corporate greed is taking precedence over consumer well-being.

I strongly urge the MPUC commission to limit Xcel Energy's exorbitant rate increase. As justification, I direct your attention to supporting documentation concerning the drop in costs of goods sold, the high costs and perquisites of corporate staff, the overall continued low inflation rate of the economy, the insistence of an unrealistic rate of return to stockholders, and the overall lowering of real household income (including, but not limited to, retirees). I think it's time for the Commission to step up and defend the citizens of the State of Minnesota from these egregious acts of greed from a government-regulated monopoly.

Not mentioned in previous comments, but of considerable concern, is the continued rise in the costs of non-energy-related activities that Xcel is being asked to provide. Two notable activities are the Affordability Charge, and the collection of City Fees. Household income-related programs (revenue collection or administration) should not apply to Xcel's provision of natural gas and electricity. At a minimum, the MPUC should encourage the Affordability Charge be eliminated from utility bills, and placed back under the purview of elected representatives.

Similarly, Xcel's City Fee-collection activities are not consistent with an energy-providing monopoly's mission. Perhaps it is an efficient tax collection method, but any approval of increases in the administrative costs to collect these non-energy taxes/fees should be by elected representatives. In particular, there should not be an indiscriminate application of a percentage increase for operational costs. I implore the MPUC to fully review this topic. Consider making the tax collection activity by Excel a flat-rate cost, and not subject to Transit, County, and State tax rate application (remove them from the tax basis). Administrative cost increases to the flat-rate should then be subject to elected representatives' approval, outside of energy-related rate requests. This will help focus the MPUC on energy costs, and place accountability where it belongs: with elected representatives. Thank you for the opportunity to comment, and I appreciate the work of the dedicated members and staff of the MPUC.

I recommend that the MPUC deny Xcel Energy's request for the three or five year rate increase. The residential portion of this increase is significant and cannot be passed along to others. It is an extremely regressive "tax". Instead, can Xcel implement a graded increase based on usage with the ability to apply for credits for those with medical needs?

These utility rate increases are getting out of hand. PLEASE deny Xcel Energy's rate increase. Their pamphlet can spin it any way they want, but I am sure that alot of this increase goes toward wages. There bottom line increases every year. If that is the case they should decrease our rates. Also, how is it fair that they can increase the rates before it is even approved.

After watching the French Revolution on PBS last night and watching all of the Aristocracy get their heads cut off, I am bout to the point that I am ready to encourage the young people of this world to sharpen their Guillotines and swords and prepare for revolution. It seems there is no end to the American Public getting ripped-off by the 1 percent. The 1 percent definitely needs to be put in their place once again and I hope to see it in my lifetime. Greed has totally consumed our culture and its time for a change... at any cost ! VOTE FOR BERNIE and SHARPEN YOUR SWORD !

Xcel Energy has yet once AGAIN asked for another huge rate increase – every year – for another three years out into the future. The Minnesota Public Utilities Commission (MPUC) has just given a huge 3-year rate increase to this rapacious energy company. MPUC needs to do a much better job of it this time, and deny every penny of the requested rate increase. Xcel Energy has not given any real reason for asking for a rate increase. All they say is maintaining and upgrading its system, a catchall that means anything, or nothing. Many commenters have given many excellent technical reasons for denying this rate increase. MPUC needs to consider more than just technicals. There is too much of a crushing financial burden on a lot of residents in this request for yet another huge rate increase, especially in view of what happened to too many people in the midst of the last huge rate increase given to Xcel Energy.

It was a very bad mistake, and a savage blow, to a lot of Plymouth residents, for the city to impose a $2.00 per Xcel Energy account per month NEW tax on residents. The mayor and the city council members would not own up to the fact that it was a $2.00 per Xcel Energy account per month new, additional TAX on residents. Instead, they tried to hide the human side of it by calling it a franchise fee on tax-exempt properties. A $2.00 per month new tax, if it were to meet their (dubious) standard of 1.9% to 2% tax levy increase, would require an Excel Energy account with a monthly bill of $100. My monthly bills have been $18.67 (due 06/13/14 for 04/16/14 - 05/15/14), $23.33, $27.02, and $20.63 (due 09/12/14 for 07/16/14 - 08/14/14) INCLUDING their wicked $2.00 per month additional tax. Without that $2.00 per month additional tax, those bills would have been $17.64, $21.33, $25.02, and $18.63. NOTE that these bills are for the SUMMER months of June and July and through mid-August. You need to know that starting in summer 2013, I never allowed my air conditioner to be run for even one MINUTE the entire summer because the air-conditioner is by far the worst energy guzzler of anything in my poor humble apartment. Same for summer 2014. Same for summer 2015. (If I had run the air conditioner even just a little, those bills quoted above would have been $10.00 to $15.00 per month HIGHER.) [You ought to know that one of the most frequent causes of DEATH for senior citizens on limited fixed income is in fact summertime heat stroke, heat exhaustion, because they either don't have air conditioning or can't afford the huge hit to their monthly energy bill that running an air conditioner causes. And, by the way, don't bother to blab about Xcel Energy’s Saver's Switch - it doesn't help anywhere near enough! And of course no landlord would ever allow any such thing anyway.] So, in their career-politician fever, not only for ever more and more revenue, but also for even more "diversified" sources of revenue, they imposed a new tax that is remarkably unfair because it taxes a whole class of citizens at a punitive rate of 12% or more - atrocious even by their jaded standards. And their timing for it couldn't possibly have been worse because they made it to coincide with Xcel Energy's latest in an all-too-frequent set of rate increases, the last of which even the regulators PUBLICLY said was WAY OUT OF LINE UNJUSTIFIED WAY TOO MUCH!

MPUC was right when they publicly blasted Xcel Energy back then, but MPUC failed to follow through and caved in to the demands of Xcel Energy, giving them way too much rate increase. If MPUC still can’t get it right this time, and deny the rate increase request in its entirety, then MPUC needs to deny all rate increase on all individual Xcel Energy accounts that are less than $75 per month, as calculated BEFORE any rate increase.

As both a rate payer and a shareholder I am appalled by the executive compensation at Xcel. Over the past three years the CEO has averaged $12,682,403 in annual compensation while the top four officers have averaged approximately $2,500.000 per annum. Based on the materials in my annual report, Xcel is engaged solely in regulated monopoly endeavors. It strains my imagination to believe that anyone deserves this level of pay when they are running an entity with no competition. I feel that this must be taken under consideration when determining if a rate increase is warranted.

Unless you are projected to fail to turn a profit in the next 3 years there is no reason to increase rates. The fact you have a monopolized commodity and you wish to increase rates without properly justifying such a change is unethical. Honestly, Xcel should be not-for-profit since we don't get to choose our power company. Regardless of that you should maintain prices and skip the greed.

Xcel does not need a rate increase every year, they need to quite sending me mailers that I use more energy than my neighbors and put that money to work for the company. I have 9 people in my house and most households around me have 2 or 3 members we do conserve energy. I can't get a 2% raise at work and yet I am asked for nearly 20% more for basic electricity. It is time for investors to stop asking for the moon while the rest of use barely get by.

here we go again-yet another proposed rate increase which is anything but reasonable. A rate increase per year of NOT MORE than 2% is reasonable.

Compelling direct testimony from Mr. Lindell and Mr. Nelson from OAG and from Ms. Brockway (representing AARP). I hope the Commission takes pause to reflect on (and endorse) the high level insights provided!

If rate increases are needed, then please apply the increases to the "Per KWH" rate instead of the fixed "monthly customer charge" rate. This would increase the incentive to conserve energy, lower overall energy use, and boost participation in conservation programs.

Doing my best to conserve energy in my home, I have: installed high efficiency windows, replaced hot water heater, used Saver Switch, installed LED lights, and installed a programmable thermostat. I also installed solar panels on my residence. I've done these things because conserving energy, rather than needlessly wasting it, is the right thing to do.

An increase to "monthly customer charge" rates destroys incentive to conserve energy. I have cut my monthly bill to be much less that the $71 average (listed by Xcel), so a 13% increase (listed by Xcel) is more like a 30% or more increase to people trying to do the right thing. These "monthly customer charge" increases drastically destroy the incentive to conserve energy. As it is now, if I increased my energy use by 50%, my bill would only increase about 10%. If I decreased my energy use by 50%, my bill would only decrease about 10%. Most of my bill is the "monthly customer charge" component, so there is no fiscal incentive to conserve.

Reading the Rate Increase Notice for E0002/GR-15-826, I noticed a difference in price between Residential and Small General Commercial Customer Energy (PER KW) Rates. I would ask the PUC to ask why these rates are not the same? Why do businesses need a rate discount up to a 10.2%?

Absolutely not, no rate increases are needed. Xcel needs to cut their own expenses and not pass things on to the consumer. There has to be ways for Xcel to work on lowering their budget (less advertising, no bonuses, etc, etc)

I respectfully urge the MPUC to reject or drastically reduce this proposed rate increase. It appears to me that Xcel's business plan includes a standard yearly rate increase request, whether it can be justified or not.

Continually granting these requests, even at a reduced rate, insures that Xcel has no incentive to manage their budget, much less reduce their costs. Since the shareholders are guaranteed a profit, the fiscal responsibility that most publicly owned companies feel towards their shareholders is absent at Xcel. Nothing has made this clearer to me than the gross mismanagement of the Monticello upgrade, and the rate hikes to compensate for lost revenue caused by consumer energy conservation.

Why is Xcel paying millions to have their name on a sports center along with reduced power rates. We have no choice to choose a different power company that is cheaper rates. But get to fund their name on a building.

How long will this charade continue? The MN Legislature's 2013 renewable energy mandate (1.5% of renewables by 2020) has trapped the 5 MN. electricity providers into the community solar garden fallacy. This necessitates large amounts of infrastructure updates to increase sub station capacity. All this takes significant amount of labor and material to accomplish. All predicated on the canard of global warming. As these solar gardens continue to be developed, one can see rate increase requests for the foreseeable future. Certainly a cost/benefit analysis was not considered as who could be against saving Mother Earth? One can see how this devotion to voodoo science can affect our lives. When government steps in with a mandate, they unwittingly upset the market. Of course the consumer always pays for their incompetence. How many members of the MPUC are "in the tank" and believers of global warming and how will they approach Xcels rate increase request? I see no reason to be hopeful for any rate leveling off. Saving the Mother from the "big lie" is an expensive undertaking.

Thank you got considering our concerns. This request appears unwarranted, since the company provided no reasons for their desired increase. An increase could seem reasonable to a consumer if company expenses had increased, or if they were investing in improved services. It appears that their costs for materials have declined. I could support a modest labor cost increase. It's disconcerting that consumer service delivery has not improved. I hear of no efforts to move overhead lines underground. When we have a nasty storm, the same areas, usually older neighborhoods, experience outages; both the utility and the customers incur extra expenses and labor, plus great inconvenience. Customers' expenses spill over into other areas of the economy, yet the company has taken no preventative steps. I would like to see some aggressive efforts from NSP to upgrade delivery systems as well as know what they plan to do with the requested additional money. Thank you again for listening.

I testified at the hearing in Red Wing on July 27. I am submitting the attached letter as my additional comments. The solution to high rates in MN is simple. Deregulate and let the free market determine rates. Rates in Texas are less than half of rates in Minnesota. Deregulation works in Texas and it can work in Minnesota also.

Thanks, Joseph Fishback

I testified at the hearing in Red Wing on July 27. I am submitting the attached letter as my additional comments. The solution to high rates in MN is simple. Deregulate and let the free market determine rates. Rates in Texas are less than half of rates in Minnesota. Deregulation works in Texas and it can work in Minnesota also.

Thanks, Joseph Fishback

I was not sure my attachment was posted so here is the text of the attachment pasted into the response field: There are some formatting issues with the pasted version but the text is correct. Thanks, Joseph Fishback

                            2785 Ide Lane
                            Red Wing, MN 55066
                            August 1, 2016

Clark D. Kaml, Rates Analyst Minnesota Public Utilities Commission 121 7th Place East, Suite 350 St. Paul, MN 55101-2147

Nancy Campbell, Financial Analyst Minnesota Department of Commerce Division of Energy Resources 85 7th Place East, Suite 500 Saint Paul MN 55101-2198

Jeffrey Oxley, Administrative Law Judge Office of Administrative Hearing P.O. Box 64620 St. Paul, Minnesota 55164-0620

RE: Northern States Power Company Rate Case, PUC Docket No. E002/GR-15-826 OAC Docket No. 19-2500-33074 My name is Joseph William (Bill) Fishback II. I represent myself as an electric utility rate payer living in Red Wing, MN. I provided oral testimony in this rate case at the public hearing held on July 27, 2016 at Southeast Technical College, in Room 314 located at 308 Pioneer Road in Red Wing, MN 55066.

By this letter, I wish to reiterate in writing for the public docket the oral testimony that I provided and add some additional thoughts for your consideration.

As you will recall, I documented that there is a significant disparity between electric rates in Texas and Minnesota. In Red Wing, rate payers pay between 14 and 15 cents per kilowatt hour (KWH) for the total delivered cost of electricity. In Richardson, Texas (a Dallas suburb) my daughter pays between 6 and 7 cents per KWH for the total delivered cost of electricity. Electricity production and distribution in Texas has been deregulated and, as a result, residents there enjoy the option of choosing between dozens of electricity suppliers and dozens of rate plans which they can customize to meet their specific needs and monthly KWH demand history. Earlier this year I helped my daughter choose between the rate plans available to her and, as a result, we lowered her annual electricity bill by ~$1000. Unfortunately for all rate payers in Minnesota this flexibility does not exist.

It should be obvious that the key difference between Minnesota and Texas in regard to electricity rates is the lack of competition (i.e. monopoly) that Northern States Power Company d/b/a/ XCEL Energy enjoys in Minnesota. The Minnesota Public Utilities Commission is charged with protecting the rate payers against the otherwise unfair advantage that a monopoly would have to charge any price they chose. Of course, there is also a Texas Public Utilities Commission. However, it is obvious from comparison of the rates in the two states that the Texas PUC has been successful in protecting rate payers and the Minnesota PUC has not.

The simple question is:

“If electric rates can be reduced by over 50% in Texas, why not in Minnesota?”

The simple answer is:

• Deregulate electricity production and distribution in Minnesota. • Introduce true competition into the market place.

I have a Master’s Degree in Chemical Engineering and spent my 45 year professional career in the petroleum refining industry. There are significant similarities between the petroleum refining industry and the electric power generation industry. Both produce a commodity used by everyone every day. Both require billions of dollars of capital investment to safely and reliably deliver their products to market. Both acquire their fuel supplies and distribute their products over thousands of miles of distribution networks. Both are highly regulated by the Environmental Protection Agency at the Federal level and the various State Pollution Control Agencies for air emissions, water discharges, and solid and hazardous waste disposal. Both are comprised of many separate companies which issue common stock and are publicly held corporations responsible to stock holders. Therefore both industries are subject to the same regulatory, economic, financial, social, and geographic requirements and constraints.

Deregulation of the Petroleum Industry

However, in the petroleum refining industry, unlike XCEL in Minnesota, one petroleum company does not have a monopoly in any State. In 1911, in a precedent-setting antitrust case brought against Standard Oil and John D. Rockefeller under the Sherman Antitrust Act, the Standard Oil Trust was abolished and split into multiple competing companies. Each of those companies remains a viable competitor in the marketplace today and has prospered significantly without the benefits of an unfair monopoly.

Deregulation of the Airline Industry

When the airline industry was deregulated by Jimmy Carter’s signature on legislation on Oct 24, 1978, Southwest Airlines (which had been incorporated in 1971) became a significant competitor in that business. As a result, to this day, any market into which Southwest Airlines enters experiences lower fares. This phenomenon even has a name: “The Southwest Effect”.

Deregulation of the Telephone Industry

The breakup of the Bell System was mandated on January 8, 1982, by a consent decree which provided that AT&T Corporation would, as had been initially proposed by AT&T, relinquish control of the Bell Operating Companies that had provided local telephone service in the United States and Canada up until that point. This effectively took the monopoly that was the Bell System and split it into entirely separate companies that would continue to provide telephone service. AT&T would continue to be a provider of long distance service, while the now independent Regional Bell Operating Companies (RBOCs) would provide local service, and would no longer be directly supplied with equipment from AT&T subsidiary Western Electric. This divestiture was initiated by the filing in 1974 by the United States Department of Justice of an antitrust lawsuit against AT&T.

AT&T was, at the time, the sole provider of telephone service throughout most of the United States. Furthermore, most telephonic equipment in the United States was produced by its subsidiary, Western Electric. This vertical integration led AT&T to have almost total control over communication technology in the country, which led to the antitrust case, United States v. AT&T. The plaintiff in the court complaint asked the court to order AT&T to divest ownership of Western Electric.

Because AT&T believed that it was about to lose the suit, AT&T proposed an alternative — the breakup of the biggest corporation in American history. It proposed that it retain control of Western Electric, Yellow Pages, the “Bell” trademark, Bell Labs, and AT&T Long Distance and that it be freed from a 1956 anti-trust consent decree that barred it from participating in the general sale of computers. In return, it proposed to give up ownership of the local operating companies. This last concession, it argued, would achieve the Government's goal of creating competition in supplying telephone equipment and supplies to the operative companies. The settlement was finalized on January 8, 1982, with some changes ordered by the court decree: i.e. the regional holding companies got the Bell trademark, Yellow Pages, and about half of Bell Labs.

Effective January 1, 1984, the Bell System’s many member companies were variously merged into seven independent "Regional Holding Companies", also known as Regional Bell Operating Companies (RBOCs), or "Baby Bells". This divestiture reduced the book value of AT&T by approximately 70%.

Electric Deregulation in Texas

Included within deregulation legislation in Texas (Senate Bill 7 or “SB7”) which became law on January 1, 2002 was the concept of the "price to beat" or “PTB”, i.e. the minimum price the utilities existing prior to deregulation could charge after deregulation.

According to established economic theory, prices are optimally determined in a fair and transparent market, and not by a political or academic body. In deregulation of electricity markets, one immediate concern with pricing is that existing electricity providers would undercut the prices of new entrants, thus preventing competition and perpetuating the existing monopoly of providers. Thus, SB7 introduced a phase-in period during which a minimum price would be established (for existing electricity companies) to prevent this predatory practice, allowing new market entrants to become established. New market entrants could charge a price below the PTB, but existing providers could not. This period was to last from 2002 to January 1, 2007. How is the “price to beat” established? In order to encourage entry into the market by competitors, the PTB would have to be high enough to allow for a modest profit by new entrants. Thus, the PTB had to be above the cost of fuels such as natural gas and coal and the cost of capital and all costs associated with electrical power generation per KWH. For example, a PTB fixed at the actual wholesale procurement price of electricity does not give potential entrants a margin to compete against existing utilities. Second, the PTB would have to be reasonably low, to enable as many customers as possible to continue to consume electricity during the transition period.

One desired effect of the competition is lower electricity rates. In the first few years after the deregulation in 2002, the residential rate for electricity increased seven times, with the PTB at around 15 cents per kilowatt hour (as of July 26, 2006, www.powertochoose.org) in 2006. However, while prices to customers increased 43% from 2002 to 2004, the costs of fuels rose faster, by 63%, showing that not all increases have been borne by consumers.

In June 2016 the Texas Coalition for Affordable Power (TCAP) found that Texans living in areas with retail electric deregulation consistently paid higher average electric rates than Texans living in deregulation-exempt areas. This trend had held for every year from 2002, the very first year of retail electric deregulation, through 2014. TCAP did not conduct an analysis for 2015 and 2016 because the necessary underlying data had not yet been released by the United States Energy Information Administration. However, the TCAP report did identify dozens of competitive deals during 2016 with prices meeting or beating those common in deregulation-exempt areas. It found that the number of those comparatively affordable deals in deregulated areas had increased in recent years. TCAP likewise found that the gap between average deregulated and non-deregulated residential prices in Texas had narrowed substantially in recent years.

Compared to the rest of the nation, data from the U.S. Energy Information Administration which publishes annual state electric prices that show that Texas' electric prices did rise above the national average immediately after deregulation from 2003 to 2009, but, from 2010 to 2015 have moved significantly below the national average price per kWh, with a total cost of $0.0863 per kWh in Texas in 2015 vs. $0.1042 nationally, or 17 percent lower in Texas. My daughter in Richardson now pays < $0.07 per KWH.

The PTB accomplished its goal of attracting competitors to the market during the period through January 1, 2007. It allowed competitors to enter the market without allowing the existing providers to undercut them in price. It has also given energy consumers the ability to compare energy rates offered by different providers. The less-regulated providers undercut the PTB by only a small margin given that they must balance lower prices (to attract customers and build market share) with higher prices (needed to reinvest in new power plants). Due to the small difference in competing prices and slow (yearly or so) "buying" process, price decrease due to competition was very slow, and it took a few years to offset the original increase by "traditional" electric providers and move to lower rates.

One of the benchmarks of a successful free market is the range of choice provided to customers. Choice can be viewed both in terms of the number of firms active in the market as well as the variety of products those firms offer to consumers. In the first decade of retail electric deregulation in Texas, the market experienced dramatic changes in both metrics. In 2002, residential customers in the Dallas-Fort Worth area could choose between 10 retail electric providers offering a total of 11 price plans. By the end of 2012, there were 45 retail electric providers offering 258 different price plans to residential customers in that market. Similar increases in the number of retail electric providers and available plans have been realized in other deregulated electricity market areas with the state.

In conclusion, I give credit to Wikipedia for some of the historical information in this letter supporting my arguments for deregulation.

Therefore, what can we learn from the history of deregulation of gigantic monopolies in the United States? Every time deregulation occurs, competition ensues, and prices go down, the consumer benefits, choices increase, and safety and reliability are maintained.

Everyone would take notice and be very concerned if gasoline cost $2 per gallon in Texas and $4 per gallon in Minnesota at the same time. Yet this doubling of cost is exactly what is happening today with electricity rates between the two states. If there was only one gasoline retailer in the State of Minnesota, the only result would be higher prices.

As they say, “This is not rocket science”. And we do not have to “reinvent the wheel”. We have a successful Texas model to study and follow and implement. We must deny the rate increase requested by XCEL energy and, instead implement electricity deregulation in Minnesota as quickly as possible. Even this result allows XCEL to keep all of the excessive charges they have accumulated over the years until deregulation is implemented. That is quite a windfall for something that should have been illegal from the beginning.
Sincerely,

                            Joseph W. Fishback II
                            Landline    651-388-7809

I was not sure my attachment was posted so here is the text of the attachment pasted into the response field: There are some formatting issues with the pasted version but the text is correct. Thanks, Joseph Fishback

                            2785 Ide Lane
                            Red Wing, MN 55066
                            August 1, 2016

Clark D. Kaml, Rates Analyst Minnesota Public Utilities Commission 121 7th Place East, Suite 350 St. Paul, MN 55101-2147

Nancy Campbell, Financial Analyst Minnesota Department of Commerce Division of Energy Resources 85 7th Place East, Suite 500 Saint Paul MN 55101-2198

Jeffrey Oxley, Administrative Law Judge Office of Administrative Hearing P.O. Box 64620 St. Paul, Minnesota 55164-0620

RE: Northern States Power Company Rate Case, PUC Docket No. E002/GR-15-826 OAC Docket No. 19-2500-33074 My name is Joseph William (Bill) Fishback II. I represent myself as an electric utility rate payer living in Red Wing, MN. I provided oral testimony in this rate case at the public hearing held on July 27, 2016 at Southeast Technical College, in Room 314 located at 308 Pioneer Road in Red Wing, MN 55066.

By this letter, I wish to reiterate in writing for the public docket the oral testimony that I provided and add some additional thoughts for your consideration.

As you will recall, I documented that there is a significant disparity between electric rates in Texas and Minnesota. In Red Wing, rate payers pay between 14 and 15 cents per kilowatt hour (KWH) for the total delivered cost of electricity. In Richardson, Texas (a Dallas suburb) my daughter pays between 6 and 7 cents per KWH for the total delivered cost of electricity. Electricity production and distribution in Texas has been deregulated and, as a result, residents there enjoy the option of choosing between dozens of electricity suppliers and dozens of rate plans which they can customize to meet their specific needs and monthly KWH demand history. Earlier this year I helped my daughter choose between the rate plans available to her and, as a result, we lowered her annual electricity bill by ~$1000. Unfortunately for all rate payers in Minnesota this flexibility does not exist.

It should be obvious that the key difference between Minnesota and Texas in regard to electricity rates is the lack of competition (i.e. monopoly) that Northern States Power Company d/b/a/ XCEL Energy enjoys in Minnesota. The Minnesota Public Utilities Commission is charged with protecting the rate payers against the otherwise unfair advantage that a monopoly would have to charge any price they chose. Of course, there is also a Texas Public Utilities Commission. However, it is obvious from comparison of the rates in the two states that the Texas PUC has been successful in protecting rate payers and the Minnesota PUC has not.

The simple question is:

“If electric rates can be reduced by over 50% in Texas, why not in Minnesota?”

The simple answer is:

• Deregulate electricity production and distribution in Minnesota. • Introduce true competition into the market place.

I have a Master’s Degree in Chemical Engineering and spent my 45 year professional career in the petroleum refining industry. There are significant similarities between the petroleum refining industry and the electric power generation industry. Both produce a commodity used by everyone every day. Both require billions of dollars of capital investment to safely and reliably deliver their products to market. Both acquire their fuel supplies and distribute their products over thousands of miles of distribution networks. Both are highly regulated by the Environmental Protection Agency at the Federal level and the various State Pollution Control Agencies for air emissions, water discharges, and solid and hazardous waste disposal. Both are comprised of many separate companies which issue common stock and are publicly held corporations responsible to stock holders. Therefore both industries are subject to the same regulatory, economic, financial, social, and geographic requirements and constraints.

Deregulation of the Petroleum Industry

However, in the petroleum refining industry, unlike XCEL in Minnesota, one petroleum company does not have a monopoly in any State. In 1911, in a precedent-setting antitrust case brought against Standard Oil and John D. Rockefeller under the Sherman Antitrust Act, the Standard Oil Trust was abolished and split into multiple competing companies. Each of those companies remains a viable competitor in the marketplace today and has prospered significantly without the benefits of an unfair monopoly.

Deregulation of the Airline Industry

When the airline industry was deregulated by Jimmy Carter’s signature on legislation on Oct 24, 1978, Southwest Airlines (which had been incorporated in 1971) became a significant competitor in that business. As a result, to this day, any market into which Southwest Airlines enters experiences lower fares. This phenomenon even has a name: “The Southwest Effect”.

Deregulation of the Telephone Industry

The breakup of the Bell System was mandated on January 8, 1982, by a consent decree which provided that AT&T Corporation would, as had been initially proposed by AT&T, relinquish control of the Bell Operating Companies that had provided local telephone service in the United States and Canada up until that point. This effectively took the monopoly that was the Bell System and split it into entirely separate companies that would continue to provide telephone service. AT&T would continue to be a provider of long distance service, while the now independent Regional Bell Operating Companies (RBOCs) would provide local service, and would no longer be directly supplied with equipment from AT&T subsidiary Western Electric. This divestiture was initiated by the filing in 1974 by the United States Department of Justice of an antitrust lawsuit against AT&T.

AT&T was, at the time, the sole provider of telephone service throughout most of the United States. Furthermore, most telephonic equipment in the United States was produced by its subsidiary, Western Electric. This vertical integration led AT&T to have almost total control over communication technology in the country, which led to the antitrust case, United States v. AT&T. The plaintiff in the court complaint asked the court to order AT&T to divest ownership of Western Electric.

Because AT&T believed that it was about to lose the suit, AT&T proposed an alternative — the breakup of the biggest corporation in American history. It proposed that it retain control of Western Electric, Yellow Pages, the “Bell” trademark, Bell Labs, and AT&T Long Distance and that it be freed from a 1956 anti-trust consent decree that barred it from participating in the general sale of computers. In return, it proposed to give up ownership of the local operating companies. This last concession, it argued, would achieve the Government's goal of creating competition in supplying telephone equipment and supplies to the operative companies. The settlement was finalized on January 8, 1982, with some changes ordered by the court decree: i.e. the regional holding companies got the Bell trademark, Yellow Pages, and about half of Bell Labs.

Effective January 1, 1984, the Bell System’s many member companies were variously merged into seven independent "Regional Holding Companies", also known as Regional Bell Operating Companies (RBOCs), or "Baby Bells". This divestiture reduced the book value of AT&T by approximately 70%.

Electric Deregulation in Texas

Included within deregulation legislation in Texas (Senate Bill 7 or “SB7”) which became law on January 1, 2002 was the concept of the "price to beat" or “PTB”, i.e. the minimum price the utilities existing prior to deregulation could charge after deregulation.

According to established economic theory, prices are optimally determined in a fair and transparent market, and not by a political or academic body. In deregulation of electricity markets, one immediate concern with pricing is that existing electricity providers would undercut the prices of new entrants, thus preventing competition and perpetuating the existing monopoly of providers. Thus, SB7 introduced a phase-in period during which a minimum price would be established (for existing electricity companies) to prevent this predatory practice, allowing new market entrants to become established. New market entrants could charge a price below the PTB, but existing providers could not. This period was to last from 2002 to January 1, 2007. How is the “price to beat” established? In order to encourage entry into the market by competitors, the PTB would have to be high enough to allow for a modest profit by new entrants. Thus, the PTB had to be above the cost of fuels such as natural gas and coal and the cost of capital and all costs associated with electrical power generation per KWH. For example, a PTB fixed at the actual wholesale procurement price of electricity does not give potential entrants a margin to compete against existing utilities. Second, the PTB would have to be reasonably low, to enable as many customers as possible to continue to consume electricity during the transition period.

One desired effect of the competition is lower electricity rates. In the first few years after the deregulation in 2002, the residential rate for electricity increased seven times, with the PTB at around 15 cents per kilowatt hour (as of July 26, 2006, www.powertochoose.org) in 2006. However, while prices to customers increased 43% from 2002 to 2004, the costs of fuels rose faster, by 63%, showing that not all increases have been borne by consumers.

In June 2016 the Texas Coalition for Affordable Power (TCAP) found that Texans living in areas with retail electric deregulation consistently paid higher average electric rates than Texans living in deregulation-exempt areas. This trend had held for every year from 2002, the very first year of retail electric deregulation, through 2014. TCAP did not conduct an analysis for 2015 and 2016 because the necessary underlying data had not yet been released by the United States Energy Information Administration. However, the TCAP report did identify dozens of competitive deals during 2016 with prices meeting or beating those common in deregulation-exempt areas. It found that the number of those comparatively affordable deals in deregulated areas had increased in recent years. TCAP likewise found that the gap between average deregulated and non-deregulated residential prices in Texas had narrowed substantially in recent years.

Compared to the rest of the nation, data from the U.S. Energy Information Administration which publishes annual state electric prices that show that Texas' electric prices did rise above the national average immediately after deregulation from 2003 to 2009, but, from 2010 to 2015 have moved significantly below the national average price per kWh, with a total cost of $0.0863 per kWh in Texas in 2015 vs. $0.1042 nationally, or 17 percent lower in Texas. My daughter in Richardson now pays < $0.07 per KWH.

The PTB accomplished its goal of attracting competitors to the market during the period through January 1, 2007. It allowed competitors to enter the market without allowing the existing providers to undercut them in price. It has also given energy consumers the ability to compare energy rates offered by different providers. The less-regulated providers undercut the PTB by only a small margin given that they must balance lower prices (to attract customers and build market share) with higher prices (needed to reinvest in new power plants). Due to the small difference in competing prices and slow (yearly or so) "buying" process, price decrease due to competition was very slow, and it took a few years to offset the original increase by "traditional" electric providers and move to lower rates.

One of the benchmarks of a successful free market is the range of choice provided to customers. Choice can be viewed both in terms of the number of firms active in the market as well as the variety of products those firms offer to consumers. In the first decade of retail electric deregulation in Texas, the market experienced dramatic changes in both metrics. In 2002, residential customers in the Dallas-Fort Worth area could choose between 10 retail electric providers offering a total of 11 price plans. By the end of 2012, there were 45 retail electric providers offering 258 different price plans to residential customers in that market. Similar increases in the number of retail electric providers and available plans have been realized in other deregulated electricity market areas with the state.

In conclusion, I give credit to Wikipedia for some of the historical information in this letter supporting my arguments for deregulation.

Therefore, what can we learn from the history of deregulation of gigantic monopolies in the United States? Every time deregulation occurs, competition ensues, and prices go down, the consumer benefits, choices increase, and safety and reliability are maintained.

Everyone would take notice and be very concerned if gasoline cost $2 per gallon in Texas and $4 per gallon in Minnesota at the same time. Yet this doubling of cost is exactly what is happening today with electricity rates between the two states. If there was only one gasoline retailer in the State of Minnesota, the only result would be higher prices.

As they say, “This is not rocket science”. And we do not have to “reinvent the wheel”. We have a successful Texas model to study and follow and implement. We must deny the rate increase requested by XCEL energy and, instead implement electricity deregulation in Minnesota as quickly as possible. Even this result allows XCEL to keep all of the excessive charges they have accumulated over the years until deregulation is implemented. That is quite a windfall for something that should have been illegal from the beginning.
Sincerely,

                            Joseph W. Fishback II
                            Landline    651-388-7809

I am just hearing about this. Intentional community engagment should have been sought. I hope to see Xcel engage in stakeholder meetings or roundtables with the communities.

I think a 20% increase is not necessary nor indicated. As others have pointed out it seems that Xcel energy is always asking for rate increases and always getting them. The cost of many oil and gas is depressed now. Shouldn't this translate to lower costs for the power company? Please deny this request and require a real showing of necessity in the future. This is a public utility with a monopoly. Stock is doing well and executives are well paid. What is the necessity?